2006 ANNUAL REPORT TO ACNCG
2005 AUDIT PROGRAM4
ENVIRONMENT IMPROVEMENT PLAN (EIP) 5
EPA WASTE DISCHARGE LICENCE8
EPA LICENCE NON CONFORMANCES8
VOLATILE ORGANIC COMPOUND EMISSIONS8
WATER RESOURCE MANAGEMENT10
PLASTICS WASTE WATER IRRIGATION 12
CITY WEST WATER TRADE WASTE AGREEMENT 13
PRESSURE SAFETY VALVE PERFORMANCE15
SOLID & EPA PRESCRIBED WASTES15
ENERGY EFFICIENCY & GREENHOUSE GASES17
GROUNDWATER MANAGEMENT PLAN18
COMMUNITY RIGHT TO KNOW AND COMMUNIY INTERFACES19
PERSONAL SAFETY PERFORMANCE20
MAJOR HAZARDS FACILITIES (MHF ) REGULATIONS23
DANGEROUS GOODS STORAGE25
SH & E INCIDENTS 26
2005 was a year of high activity for Qenos Altona. The SCAL-1 plant conversion to gas feed progressed through the year. Substantial installation of equipment in the SCAL-1 plant was completed during the first nine months of the year while the plant was still producing product. Completion of this work required a peak contract workforce of 700 people for a two month period during the turnaround.
Gas oil feed was last processed in the SCAL-1 plant on September 30th when the plant was shutdown for the turnaround and completion of the conversion to Ethane & LPG feedstock. The SCAL-1 turnaround was completed on schedule and the plant conversion continued with start up scheduled in February 2006.
The Elastomers plant was shutdown on September 8th and the last bale of synthetic rubber was produced in Australia. The Elastomers plant was fully decommissioned with zero harm to the environment and isolated from all external operations and utilities.
The Resins Polypropylene plant was shutdown September 26th for the last time and was decommissioned with zero harm to the environment. The permanent isolation for the polypropylene plant from ongoing operations is being completed during the first half of 2006.
An incident with the Olefins flare on October 1st resulted in 22 odour complaints during the SCAL-1 plant preparation for the turnaround. A letter drop to the affected area explaining the source of the odour was completed in the days following the incident. The investigation included an ACNCG member and a special EMT meeting was scheduled where complainants were invited to hear the outcome of the incident investigation and have an opportunity to ask questions. The November Consultative Chronicle included an article explaining the incident investigation and action items arising from the investigation. An infringement notice for breach of licencse condition of $5,245 was issued by the EPA on November 30th in relation to this incident.
Overall performance for 2005 was solid and built on the good performance of 2004 with the total number of environmental reportable incidents being the second lowest with 8 incidents compared to 7 in 2004. (See Figure 1 Below)
Highlights of Qenos Altona performance this year are:
- 517 risk management actions for Qenos Altona were completed against a target of 460 actions.
- Plastics site has completed 6 years without a reportable incident.
- Elastomers site shutdown and decommissioned on schedule with zero harm.
- Poly Propylene plant shutdown with zero harm
- Reduced butadiene emissions. (Figure 8)
- Reduced benzene emissions. (Figure 7)
Opportunities for improvement are:
- Management of flare combustion during final equipment preparation at the Olefins site.
- Complete the conversion of SCAL-1 to LPG/Ethane feedstock which moves the plant to cleaner production by reducing emissions, solid waste, greenhouse gas production & energy consumption.
- Reduce employee & contractor injury rates.
This annual report is for 2005 operations of the four manufacturing sites at Altona, Qenos Olefins, Qenos Plastics, Qenos Resins and Qenos Elastomers.
Total production across all the sites in kilotonnes is shown in Figure 2 and includes production of hydrocarbon intermediates that are transferred to other Qenos plants as well as production of final products for sale to customers.
2005 production was low due to the SCAL-1 turnaround and conversion activities and shutdown of the polypropylene and synthetic rubber plants in September.
Qenos Olefins uses ethane gas from Bass Strait and will use Propane and Butane as feedstock post SCAL-1 conversion. Gas oil liquid from the Mobil Altona refinery will no longer be used as a feedstock eliminating a number of byproducts.
Ethylene produced will be feedstock for the Plastics and Resins polyethylene plants.
Qenos Plastics uses ethylene from the Olefins site to manufacture polyethylene. The low-pressure polymerisation plant produces high-density polyethylene (HDPE) used for products such as milk bottles, irrigation and gas piping and household containers.
Qenos Resins also produces HDPE from ethylene manufactured by Olefins using a solvent solution polymerisation process. The HDPE from Resins is used in a similar range of products to that from Plastics, but especially for mobile garbage bins.
Resins Polypropylene plant was shutdown in September. Refinery grade propylene that will be produced by the converted SCAL-1 plant will be exported to Basell who have acquired the Qenos polypropylene business.
Qenos Elastomers closed down production in September 2005 when feedstock was no longer available from the Olefins plant due to the SCAL-1 conversion.
2005 AUDIT PROGRAM
The Polymers sites had an internal assessment of the Safety, Health and Environment Operating System (SHEOS) audit in December 2005. The audit incorporates the requirements of the Safety Management System, Environment Management System and Responsible Care requirements. The Olefins site review has been deferred until post SCAL-1 start up.
The average rating for the 21 practices within SHEOS for 2005 was 3.90 (out of a possible 4.0.), which was an incremental improvement on our average rating of 3.88 for the 2004 assessment.
The audit found two areas of non compliance from the 194 SHEOS system requirements, and 106 continuous improvement opportunities to enhance the SHEOS system effectiveness.
Figure 3 shows the progression of overall SHEOS audit ratings since 1995.
A Qenos Regulatory Compliance audit of the Plastics site was completed.
The 2003 EPA accredited licence audit recommended a longer interval between Accredited License audits than the annual frequency that had been practiced. Consultation between the EPA, EMT representatives, the accredited license auditor and Qenos agreed to a two tiered accredited license audit structure. This included a full audit in the last year of a license period and a targeted mid term audit where the audit scope is agreed with the EPA prior to proceeding. The targeted mid term Accredited License audit is scheduled to occur in the first half of 2006.
The oversight program for Major Hazards Facilities was conducted by Work safe
ENVIRONMENT IMPROVEMENT PLAN (EIP)
A new format was adopted for the EIP in 2005. Rather than a three year action plan with staggered due dates for various items across those three years, an annual Environment Action Plan (EAP) was prepared, with all items expected to be completed within the 2005 calendar year. This made the regular stewarding of the plan with EPA and the community much more straightforward, and is seen as an example of how best to manage a mature EIP process once most of the more obvious action items have been addressed. This format will continue, with the 2006 EAP having been developed late in 2005.
The 2005 EAP had 32 action items at the outset. The table below summarises the status at the end of the year:Items Completed in 2005 / Deferred Items / Items continuing into 2006 / Total Items
23 / 2 / 7 / 32
A total of 23 items, or 72%, were fully completed within the calendar year. Some of the key environmental improvement achievements included:
- Commissioning of pyrolysis gasoline (pygas) burning in the Olefins boilers, with confirmation that benzene levels in stack emissions were below the levels of detection.
- Elimination of odours emanating from the Resins cooling water tower using a new treatment program
- Replacement of two Olefins effluent cooling heat exchangers with larger units, to eliminate the need for cooling water addition to the effluent during normal operation to comply with discharge temperature limits
- A number of water reduction projects at the Plastics site
- Upgrading a tar pump seal at Olefins to eliminate seal flushing oil from the process sewers, in line with the No Oil To Sewer (NOTS) program
In addition to this, environmental management plans were developed and implemented for the major plant shutdowns and closures taking place across all sites in 2005. This included the final closure of the Elastomers site.
Also, a number of studies were undertaken in 2005 that have now lead to specific action items in the 2006 EAP, covering some waste management issues, some new water reduction projects and effluent quality monitoring.
Some of the specific action items can be found discussed in more detail elsewhere in this report.
Two action items for the Olefins plant were deferred without starting in 2005, due to resources being unavailable during the Scal 1 turnaround and conversion project work. These were the painting of the storage sphere TK-814, deferred into the 2006 EAP, and the cleaning of the redundant effluent ponds which will now be scheduled for 2007.
The remaining seven items commenced in 2005, but were not completed at year end and continue into 2006. Four of these are linked to the completion of the Scal 1 turnaround and cannot be closed out until after the plant has started back up in early 2006. Two are linked to a water study that did not commence until much later in the year and was always expected to continue into 2006, and the last is a Plastics compressor gearbox upgrade project that missed the October shutdown window due to a long manufacturing lead time, and will be rescheduled for early 2006.
The 2006 EAP has a total of 38 action items, including those carried over from 2005.
There were 31 complaints accepted by Qenos in 2005. The incident with the Olefins flare during the shutdown of SCAL-1 on October 1st and 2nd accounted for 22 of the complaints. Three other complaints for odour were sourced to the shutdown and turnaround activities.
There were six other complaints for the nine months prior to the SCAL-1 shutdown. Of these complaints there were three in February for noise from the flares on the Olefins site. The
noise was attributed to the use of smoke suppression steam and the generally still ambient conditions. Two odour complaints were accepted for background odour from the Olefins site.
The Elastomers flare which has no smoke suppression system was in use for a short time in April following a Pressure Safety Valve discharge and a complaint for smoke was received via the EPA poll watch line.
The occurrence of the flare odour incident was disappointing and is an unwelcome blemish on the improvement being sought in reducing Qenos impact in the community.
There were nine complaints for the rest of the year which is consistent with maintaining the level achieved in 2004 where there was a total of nine complaints for the entire year.
Operation of the Olefins site flare was implicated in 25 of the 31 complaints. During 2006 a review of the operational guidelines for the flare will be undertaken to strive to reduce the community impact of the flare operation.
Three incidents were reported in 2005 in accordance with the agreed Leak and Spill reporting procedure. This is up from the lowest ever year in 2004 with 2 reportable spills however the long term trend is still downwards. Each incident was reported and discussed at the EMT meetings3/03/2005 / Resins / High pressure solvent pump casing gasket failed releasing approximately 15m3 of Exxsol D30 solvent into the pump bund. All solvent was recovered and there was no environmental harm
5/03/2005 / Olefins / Hypochlorite storage tank piping failure resulted in loss of 200-300 litres of hypo to bunded area. All hypo contained in bund, and drained to plant sewer. QIDS 110751
10/05/2005 / Olefins / Methanol tank overfilled during transfer from road tanker. 200-250 litres flowed through PSV drain line into bunded area. Methanol recovered into drums. QIDS 110936
EPA WASTE DISCHARGE LICENCE
Table 1 shows a comparison of the estimated emissions from all sites with the discharge limits specified in the EPA licence. No license limit was exceeded.
Table 1:Qenos Performance compared with EPA Licence:Compound / EPA bubble licence, tpa / 2003 emissions,
tpa / 2004 emissions,
tpa / 2005 emissions,
Ammonia / 12 / 6. / 6.4 / 6.4
Benzene / 15 / 7.4 / 5.7 / 5.4
Butadiene / 25 / 20.4 / 16.2 / 13.6
Cyclohexane / 15 / 11.3 / 13.6 / 10.0
Carbon monoxide / 426 / 218 / 219 / 212
Hydrogen Chloride / 2.3 / < 0.05 / 0.063 / 0.063
Nitrogen Oxides ( NOX) / 578 / 477 / 372 / 557
Particulates / 92 / 19.02 / 24.9 / 29.53
Sulphur dioxide / 440 / 142 / 175 / 175
Total Organic Compounds / 1500 / 709 / 719 / 719
The Nitrogen Oxide (NOX) emissions are higher in 2005. Emission monitoring of the SCAL-2 furnaces in December had higher NOX levels resulting in an average furnace NOX emission increasing from 60 to 100 gm/minute of NOX per operating furnace. Boiler emission testing of two boilers in 2005 also yielded higher results. SG-892 (No 3 boiler) tested at 150 gm/minute both pre and post Pygas burning as part of the commissioning of Pygas burning. SG-891 (No 2 Boiler) had a test result of 350 gm/minute. The result is well outside the range of all historical boiler emission test results and a review of the boiler operation at the time of the emission testing did not reveal any abnormalities. The historical average was used for emissions from this boiler. The average emissions for the Olefins site boilers increased from 100 gm/minute to 150 gm/minute on this basis. These increases are responsible for the higher NOX emissions for 2005
A more extensive stack emission program will be undertaken during 2006 to verify the accuracy of NOX emissions.
EPA LICENCE NON-CONFORMANCES
There was one licence noncompliance during 2005 when off site odours from the Olefins flare caused 22 complaints on October 1st & 2nd.
VOLATILE ORGANIC COMPOUND EMISSIONS (VOCs)
Total VOC emissions to the atmosphere from the Qenos sites are shown in Figure 5. VOCs include ethylene, propylene, propane, butadiene, ethane, styrene, benzene and the Resins solvent.
Total VOC emissions from the four sites remained static in 2005. The VOC per tonne of production has increased due to lower production caused by the turnaround, SCAL-1 conversion and plant shutdowns. This can be seen in figure 6 below
Efforts to reduce VOC emissions are focused on reducing emissions of the Class 3 indicators, benzene and butadiene, as a priority. In 2003, Qenos submitted a plan to reduce emissions of Class 3 indicators, especially butadiene, which became a Class 3 indicator in 2002. The plan gives priority to pipes carrying process streams containing benzene and butadiene in identifying and repairing leaking valves. While the threshold value above which the EPA requires a valve to be repaired is 10,000 ppm, Qenos has dropped the threshold to 200 ppm for streams containing Class 3 indicators. This is equivalent to world’s best practice.
Figure 7 shows benzene emissions and figure 8 butadiene emissions to air. Benzene & butadiene emissions continue to be reduced over time with the lower plant time on line in 2005 contributing to the lower benzene and butadiene emission rate. The benzene & butadiene data for 2002 to 2004 has been amended upwards in this report from what was reported in the last annual report. A calculation error for these compounds in those years was discovered following emission testing at the Elastomers site in July 2005. After investigation and verification of Elastomers emissions an explanatory report was sent to EPA in October 2005 and was discussed in the November EMT meeting. All other emission calculations for 2004 were verified as correct.
Benzene and butadiene emissions will reduce in 2006 with the conversion of SCAL-1 to ethane/LPG feed and the Elastomers plant closure.
Due to the substantial nature of the change to operations on the Olefins & Resins sites and the shutdown of the Elastomers sites a review of all emission calculation methods will be undertaken in 2006.
WATER RESOURCE MANAGEMENT
Water supplies in Melbourne have become increasing tighter in recent years, with permanent water restrictions now in place. While these do not directly affect Industry, as City West Water’s largest customer for freshwater usage and trade waste discharge, Qenos was very keen to reduce water consumption and improve water efficiency. Considerable achievements have been made over the past three years.
Qenos’s first priority is to reduce the amount of freshwater used across all Altona sites. This can be achieved through identifying and eliminating wastage, optimising water usage, and re-using water where possible. Effluent reduction will also correspond with freshwater usage reduction.
Water saving initiatives developed in 2003 and 2004 continued to provide good savings for most of 2005. Water usage trends can be seen in the following graph:
The program to reduce the amount of cooling water added to the Olefins sewer to meet discharge temperature limits was completed in July with the replacement of two undersized effluent stream coolers. The new larger coolers can now handle the normal effluent cooling load without the need for cooling water addition. This, combined with previous work at Olefins, gives a total effluent flow reduction of about 430 ML/year, and an equivalent freshwater usage reduction. One of these new exchangers, E964, received support funding of $51,000 through CWW from the Department of Sustainability and Environment’s Water Smart Industry Demonstration Projects fund.