MELBOURNE SITE
ANNUAL COMMUNITY
REPORT FOR 2005
Geoff Millard - Terminals
CONTENTS
PageContents / i
Distribution / ii
1. Summary / 1
2. Community Concerns / 3
3. EPA, Worksafe and Company Audits / 5
4. Major Changes to Site Plant, Equipment and Controls / 6
5. Safety and Environmental Performance / 7
5.1 Safety Incidents
5.2 Environmental Incidents
6. EPA Waste Discharges / 9
6.1 Air Discharges
6.2 Stormwater Discharges
7.0 Waste Management Performances / 11
7.1 Liquid Waste / 15
7.2 Solid Waste / 16
8. Energy Efficiency and Greenhouse Gases / 17
9. Ground Water Management Plan / 20
10. Environment Improvement Plan (EIP) Status / 22
Melbourne 2005 Community Report1
1. Summary
This annual report covers the Terminals’ Melbourne operation at CoodeIsland for the 2005 calendar year.
It was a good year both on and off-site with no lost time injuries and no major incidents on-site and no community complaints about odour concerns off-site.
Work continued on upgrading the west side facilities and the east side facility was finally shut down and remediated to EPA standards prior to handing back to Port of Melbourne Corporation for use by P&O.
There were only eight environmental incidents and five small waste discharge infringements
As a result of continued efforts being made since 2002 to reduce volatile organic compound emissions, 2005 saw no air emission non-compliances.
Greenhouse Gas emissions have been reduced by 8% and further improvements are expected.
A new Environmental Improvement Plan (EIP) was approved by the EPA and Coode Island Community Consultative Committee (CICCC) for 2005-2008 with 14 of 62 improvements completed in the first year.
Despite the major work commitment involved in the closure and remediation of the East Side, a substantial program and environmental, safety and technological improvements was maintained in 2005.
Melbourne 2005 Community Report1/23
2. Community Concerns
There were no community complaints during 2005. Historically community complaints have been associated with odours. A graph of community (odours) complaints is detailed below.
Note: These complaints represent those that could be verified as emanating from, or caused by, Terminals. For instance, in 2001 there were a further 49 complaints but no odour sources could be found at Terminals or found caused by external operation.
The reduced odour from the site is due to a commitment to continually improve the methods of treating acrylate chemicals. They include a purpose-built caustic scrubber, the two stage treatment of joining existing activated carbon VEC with existing caustic scrubbers; the addition of combustor VEC in December 2002; enclosing odorous VEC building with extraction and general higher environmental awareness.
Melbourne 2005 Community Report1/23
3. EPA, Worksafe and Company AUDITs
An EPA accredited licence audit in 2005 was carried out over three days in July and September 2005 by AWN (Air Water Noise) Consultants. This was the second audit of this type under the new accredited EPA licence. There were 42 audit recommendations this time which ranged from finding copies of missing monitoring records to installing a first flush system at the Plant C truckfill.
The oversight program for Major Hazards Facility (MHF) was conducted by WorkSafe. This included three visits and an annual licence inspection over three days by three inspectors. The overall results supported the three-month visit frequency with the visits to be more focused on the second round of MHF licence process during the next 18 months. The inspections found that control measures and Safety Management System (SMS) elements had been implemented, further opportunities were identified for over half of those control measures and two control measures were found not fully implemented or functional.
Lloyds Register audited the Melbourne site twice during 2005; a total of 4 days. The November audit resulted in Terminals gaining 3 year recertification for ISO 14001 EMS to new 2004 standard and ISO 9000 QMS. There were no major or minor non-compliances found and no follow up issues raised for the Melbourne site.
Seventeen internal audits were carried out during 2005 covering the topics of operations, maintenance, training, incident reporting, management review, work permits and environmental management systems (EMS).
Melbourne 2005 Community Report1/23
4. Major changes to site plant, equipment and controls
The Melbourne site saw major changes during 2005 with the closure and remediation of the East Side leases in preparation for the expiry of the leases on the 31 January 2006.
Despite the work required for this this major project the momentum of the CoodeIsland program was still maintained.
Some of the major achievements include:
installiation of five roofs and drainage systems over truck fills and exchanger areas to minimise waste by segregating rain water;
upgrading of all flammable tanks at Plant C including installation of impermeable liners in foundations;
refurbishment of all tanks at Plant B combustible area and upgrading of foundations with impermeable liners;
upgrading pumps, pipe work and loading systems for the above Plant B and C tank upgrades;
upgrading foundations for three flammable tanks at Plant B;
installing waste minimisation pipe work for above Plant B and C tank upgrades;
installing backup generators and emergency lighting at Plant B;
installing new power distribution boards and motor control stations at both sites;
connection of all tanks (except Tank 7) to new combustor system; and
decommissioning of boiler and carbon bed Vapour Emission Control System at plant C.
Melbourne 2005 Community Report1/23
5. Safety and environmental performance
5.1 safety incidents
At Melbourne in 2005 there were no lost time injuries and three work injuries.
One Worksafe Improvement Notice was served in relation to induction and control of truck drivers accessing the site to collect dangerous goods.
There were no Reportable Site Incidents or Prohibition/Penalty Infringement Notice/Prosecutions in 2005.
There were no Major Hazard incidents for 2005.
There were 45 internal incident reports raised during 2005 and were broken up into the following categories:
Type: / Dangerous/Unusual/Near Misses / = 33%Environmental / = 22%
Critical Control Measures / = 13%
Customer/Complaints / = 12%
Quality System / = 12%
Other / = 8%
There were two severity 3 incidents raised in 2005:
- Loss of foam when security guard found Plant B foam pumps running.
- Internal EMS audit found water results at Plant B failed dissolved oxygen criteria twice and no toxicity result on two occasions
Melbourne 2005 Community Report1/23
5.2 ENVIRONMENTAL INCIDENTS
The historical trend of environmental incidents at the site is detailed below. These are defined as spills greater than 200 litres, EPA reportable incidents (ie cause or likely to cause an offsite discharge or odour), license breaches and EPA infringement actions. As previously noted these incidents do not include odour complaints or benzene emissions exceeding historical 51g/min license condition, which regularly occurred until the thermal oxidiser (combustor) vapour emission control system was commissioned in November 2002 to treat benzene.
In 2005; there were eight environmental incidents:-
Spill of 8,000 ltrs foam concentrate (non dangerous goods) due to a blown gasket. Most of the spill was contained on the site, with a small amount on the roadway, and all material was cleaned up.One water discharge result (24 January) at Plant B failed dissolved oxygen criteria and not tested for toxicity.
One water discharge result (30 September) at Plant B failed total organic carbon (TOC) but biological oxygen demand (BOD) criteria was within limit.
One water discharge result (30 September) at Plant C failed suspended solids and dissolved oxygen but BOD was within limit.
Water discharge results (15 November) at Plants B and C failed suspended solids criteria including toxicity at Plant C.
Complaint of muddy looking water being discharged to the Maribyrnong river (18 November) despite passing criteria tests.
Monthly caustic strength tests of phenol scrubber were inadvertently not carried out during its last 3 months of service on the east side facility before decommissioning.
6. EPA WASTE DISCHARGES
6.1 AIR EMISSIONS
Tabulated below shows a comparison of the estimated air emissions from the various discharge points with the emission limits specified in revised 2004 EPA licence, Table 1. All emissions in 2005 are below the licence mass emission limits.
Waste / EPA Emission Limits (2004) / Estimated Emissions(Kgpa)
Total Mass Rate
(g/min) / Total Annual Mass Rate (Kg/annum) / 2000
-2001 / 2001
-2002 / 2002
-2003 / 2003
-2004 / 2004 / 2005
Acrylonitrile / 2 / 350 / 235 / 132 / 122 / 4 / 2 / 0
Benzene / 36 / 1500 / 6970 / 4000 / 1478 / 151 / 138 / 16
Butyl Acrylate / 1.1 / 65 / 225 / 24 / 13 / 23 / 21 / 3
Ethyl Acrylate / 0.25 / 8 / 21 / 8 / 0 / 0 / 0 / 0
Methyl Methacrylate / 1.1 / 200 / 736 / 94 / 41 / 64 / 65 / 11
Phenol / 0.055 / 6 / 2 / 2 / 3 / 2.6 / 4.2 / 2.4
Propylene Oxide / 150 / 420 / 295 / 275 / 283 / 277 / 297 / 113
Toluene Di-isocyanate / 0.015 / 0.3 / 0.1 / 0.1 / 0.1 / 0.1 / 0.1# / 0.1
Non-Speciated VOC / 530 / 9300 / 6230 / 6400 / 4820 / 2790 / 2790# / 1211
Carbon monoxide / 40 / 1100 / * / * / 510*
Total nitrogen oxides / 240 / 9500 / * / * / 1150*
Total sulphur oxides / 70 / 18000 / * / * / 3*
Notes:
- This data is based on the combustion products from the combustor VECs and the boilers based on NPI emission factors and the total natural gas fuel plus equivalent combustion value of the VOC emissions treated by the combustor. The VOC fuel is less than 5% of the natural gas mass usage and 3% of the combustion value of natural gas usage. Thus NPI emission factors seem appropriate. In addition, monitoring data covering 18 samples (54 tests) showed full compliance to and generally less than 10% of the licence emission limit. Results are detailed in Appendix F.
#the 2003/04 financial year estimated emission was used for 2004 calendar year.
These emission estimates are based on US Tanks 4.0 or API 42 software calculations as a function of storage tank dimensions, chemical physical properties, and tank container filling quantities, duration in the tank and emission treatment effectiveness.
In 2005 volatile organic compounds (VOC) were defined in accordance with the Victorian EPA definition of all hydrocarbons with a vapour pressure greater than 0.01kPa. Previously the National Pollutant Inventory (NPI) definition of hydrocarbons with a vapour pressure greater than 0.272kPa had been used. This means emission estimates for two additional chemicals were undertaken. The result was an additional 153kg total emissions to make the non- speciated VOC total of 1,211kg.
Melbourne 2005 Community Report1/23
6.2 storm WATER discharges
There were five non-compliances to the waste discharge criteria specified in the Environmental Management Manual and tabulated below.
Performance Indicator Unit / Limit/sBiochemical Oxygen Demand / 40 (mg/l) Maximum
Suspended Solids / 60 (mg/l) Maximum
Toxicity as determined by microtox / 100 Minimum
pH / 6-9
Total Organic Carbon / 40 (mg/l) Maximum
Dissolved Oxygen / 5 (mg/l) Minimum
Flow rate / 200 kilo litres/day Maximum
Temperature / Ambient
The five non-compliances were:
Plant B water discharge on 25 January failed dissolved oxygen criteria and not tested for toxicity.Plant B water discharge on 30 September failed TOC criteria but BOD within limits.
Plant B waster discharge on 15 November failed suspended solids.
Plant C water discharge on 30 September failed suspended solids, and dissolved oxygen but BOD was within criteria.
Plant C water discharge on 15 November failed suspended solids and toxicity criteria.
Most of these results were only slightly exceeded the criteria, ranging from 1 to 35 per cent over, and were due to the construction and renovation of the facility rather than any spills or substantial contamination issues.
Melbourne 2005 Community Report1/23
WASTE MANAGEMENT PERFORMANCE
The Environmental Management System (EMS) or Waste Management Plan reviews existing waste management practises and develops new targets and objectives on an annual basis.
The analysing of air emission discharge points during 2005 found no non compliances over 135 samples.
Total emissions to the atmosphere are shown below.
Total non-speciated VOC emissions to the atmosphere are shown below. These do not include the specific chemicals listed in EPA licence, Table 1, but do include all hydrocarbons with a vapour pressure greater than 0.0272 kPa (NPI definition) and in 2005 included those with a vapour pressure above 0.01kPa (Victorian EPA definition).
Melbourne 2005 Community Report1/23
Treatment systems effectiveness estimates are generally conservative and include:
Vapour return at 100%
Combustor at 99.6% but initially (2002-03) combustor efficiency factor of 99.96% was used on actual design performance effectiveness. The assumption of 99.6% has been verified by previous results and confirmed by results in 2005.
The effectiveness could be higher but the accuracy is limited by the measuring sensitivity of the outlet results.
Activated carbon bed at 90% after July 2001 and 85% previously due to workload and performance.
Caustic scrubbers for acrylates range from 85% to 90% while two in series or scrubber with activated carbon VEC scored 98.5%
Phenol scrubber at 95% and at 99.6% from July 2005 when new phenol tank (44) was commissioned and emissions treated by combustor.
PO scrubber 99%. This assumption has been verified by analysing results.
TDI ammonia scrubber plus activated carbon treatment at 99%.
Efforts to reduce VOC emissions have been focused on reducing emissions of class 3 indicators, benzene and acrylonitrile, as well as odour generators, with acrylates as a priority. As illustrated in the graph above and the following graphs this has been achieved due to:
Combustor treatment of benzene and crude benzene emissions from November 2002.
Combustor treatment of acrylate storage tank emissions at Plant B,, from December 2002 at Plant B.
Combustor treatment of acrylonitrile storage tank emissions, from June 2003.
Combustor treatment of acrylate road tanker loading emissions from December 2004.
Decomissioning of Acrylonitrile storage tank in June 2004.
Benzene and crude benzene were no longer stored nor handled from April 2005.
Storage tanks at both Plants B and C have steadily been switched to the combustor with only seven tanks at Plant B west side remaining in 2005 an the activated carbon bed system.
During 2005, the east side storage tanks were decommissioned. This included all propylene oxide (PO) storage tanks being decommissioned by April 2005.
Benzene emissions to air are graphed below and further illustrate the VOC emission findings.
Due to the significant number of odour complaints in 2001 from acrylate operations, several strategies were implemented to reduce odour (acrylate) emissions from the 10-20 acrylate storage tanks located at different parts of the site. These treatment improvements included:-
Two stage treatment process using available caustic scrubbers with activated carbon VECs.
Installing a new purpose built caustic scrubber for acrylate treatment.
Consolidating acrylates into one area to make best use of available caustic scrubbers then later combustor treatment.
Exiting the highly odorous ethyl acrylate business in late 2001.
Acrylate emissions are graphed below.
Acrylonitrile has not been stored or handled on site since 2004.
Acrylonitrile emissions are graphed below.
Melbourne 2005 Community Report1/23
7.1 LIQUID WASTE
The total EPA prescribed wastes transported from Melbourne site to an approved treatment facility are detailed in table below. Breakdown components and previous results are tabulated as a means to identify waste sources and minimisation strategies. In general terms, the Melbourne site has been undergoing major upgrading of its facilities while decommissioning and demolishing or relocating tanks on the east side of Mackenzie road. This has involved cleaning, moving and major renovations to storage tanks, major renovations to tanks and the installation of new foundations including environmental liners.
The generation of waste from this activity appears to have stabilised in 2005 with a substantial decrease of 2,293 tonnes (45%) in tank and pipeline cleaning waste. A contributing factor to this decrease appears to be the segregating storm water project that was completed in five areas in 2005. The waste from the carbon bed VEC system continues to substantially decrease (30%) with the combustor taking a more of its load. This waste stream has steadily decreased by about 45% per year over the last four years; culminating in a total waste decrease of 2,745 tonnes. In addition, corrosive washings have decreased by 28% due to propylene oxide not being stored since April 2005.
Waste Description / 2001/02Tonnes / 2002/03 tonnes / 2003/04 tonnes / 2005 tonnes / % Difference / Comments
Activated carbon / 36 / 16 / 2 / 0.4 / -80 / Load on carbon VECS low now combustor commissioned
Corrosive Washings / 240 / 1255 / 1256 / 905.9 / -28 / Propylene oxide gone
Tank & line washings (non flammable) / 746 / 1350 / 5080 / 2787.4 / -45 / Major decrease due to stability and starting to segregate stormwater
Ship first flush / 58 / 2 / 0 / Na / Customers unable to handle pure waste separately
Phenol wastes / 33 / 93 / 0 / 285.7 / substantial increase / Gone up due to Orica not taking back waste and cleaning for East Side remediation
VECS waste (flammable) / 3975 / 3342 / 1769 / 1230.3 / -30 / Load on carbon VECS low now combustor commissioned
Total / 6376 / 6067 / 8107 / 5209.7 / -36
Melbourne 2005 Community Report1/23
7.2 SOLID WASTE
The total waste transported off site in 2005 was 21.6 tonnes. The breakdown of this waste into components with comparison to previous years is tabled below.
PRESCRIBED SOLID WASTEYEARS
2001/02
(tonnes) / 2002/03
(tonnes) / 2003/04
(tonnes) / 2005 (tonnes)
Foam pigs (F100) / 1.5 / 3.8 / 7.6 / 4
Contaminated Soils including sandblasting grit (N120) / 22.9 / 2.3 / 17.5 / 17.4
Activated carbon (N210) / 16 / 2.3
Drums (N100) / 2.2
Sludges & residues (N205) / 36.5
Organic cyanides (M210) / 26.9
Polymerised acrylate (N180) / 0.2
TOTAL / 87.8 / 24.3 / 27.4 / 21.6
The upgrading of tanks, foundations and pipework causes waste from cleaning tanks/pipework, grit blasting tanks and removal of contaminated soil hot spots in accordance with our Groundwater Management Plan.
Melbourne 2005 Community Report1/23
8. ENERGY EFFICIENCY AND GREEN HOUSE GASES
A level two energy audit was undertaken on 21 October 2003 by Environmental Resources Management (ERM). The energy assessment was undertaken as part of the Victorian EPA Protocol for Environmental Management (PEM) requirements, ie. a category C of the PEM requiring a level two energy and greenhouse gas assessment. With additional information, this report was accepted by the EPA in October 2005.
Greenhouse Gas (GHG) emissions are graphed below in equivalent tonnes of CO2 emissions. These figures do not include the combustion products from treating the product vapour emissions.
These are derived from usage of natural gas for boilers (2) and combustor treatment units (2); electricity for pumps/fans/utilities and diesel for firewater pumps and forklifts/trucks. Fuel usages are converted to energy consumption (GJ) and, in turn, to GHG emissions (CO2 equivalent) using standard emission factors from the Australian Greenhouse Office (AGO) website. The last three years are tabled below and cover the period of combustor operation. The information is based on invoice meter readings. A minority of the records prior to 2005 cannot be found and these values have been estimated based on the available majority of data.