COODE ISLAND COMMUNITY
Thursday, 18th June, 2009
CICCC / Chairperson
Environment Protection Authority
General Manager, Terminals Pty Ltd
Community Rep./Committee Member
Peter La Rose
Operations Manager, Terminals Pty Ltd
Community Rep./Committee Member
Maintenance & Operations Superintendent
Community Rep./Committee Member
ITEM 1. WELCOME BY THE CHAIR, APOLOGIES & CONFIRMATION OF DRAFT AGENDA
Robin Welcome to you all and welcome to Col Brighton, Terminals Superintendent.
Apologies: Theo Pykoulas, and Carlo Fasolino.
Draft Agenda has 2 more items added:-
7. Combustor Low Fire at Night
8. Preheating liquid injection to combustors
Confirmation of draft agenda – adopted
Robin Carlo has given a copy of the Environmental Improvement Plan No. 3 with a request that if any of the community representatives would like to sign this they are most welcome to do so. I know this is something that has happened at Geelong where some community representatives have indeed signed off on the EIP and I donÕt think it is has been the usual practice here but I do not see that as any reason why you could not do it here.
George I cannot remember what happened previously when we set up the first EIP
Robin We had a debate on this 5 years ago and the view of the community reps at that time, which may well have changed, but at that time the view was if we sign it we are saying that we are totally happy with it and we are not going to go that far. Will pass the document around, there is a place just on the inside page if you wish to sign it then do so, if not then pass it on to the next person.
Bro I do not understand the rationale for signing this at all.
Robin I think the rationale is the EPA has an expectation that such plans that come through committees like this gets the support of the community; now that is the EPAÕs view but that is not necessarily the view of the committee. In the case of the TGCCC they decided they would sign not on behalf of the TGCCC but as individuals. In other words they are putting their name to a document that they think is worthwhile for guidance for improvements over the next 3 years.
George We ought to take this up with Quentin when he gets here as I thought the EPA was backing away from actually signing the EIPÕs now and I donÕt exactly know where they actually stand on it and I think what you said is true the company, the EPA and community were to get together and sign it, I have a feeling they have changed.
(Note: following the meeting Robin clarified the point with Quentin, who advised that EPA was pleased to see community committee members sign the EIP.)
ITEM 2. CONFIRM DRAFT MINUTES FOR THE MEETING 12 MARCH, 2009 AND REVIEW ACTION ITEM LIST
Robin Draft Minutes of the 12th March, 2009 adopted without change.
09/07-2 Still outstanding
06/08-1 Still outstanding
08/08-2 Warning signs – completed 12th March, 2009 meeting
08/08-3 Ruptured wharf hose – completed 12th March, 2009 meeting
11/08-1 Manifold split – completed 12th March, 2009 meeting
3/09-1 Maintenance Planner – completed 18th June, 2009 meeting discussed under Item 6.
3/09-2 Proposed schedule of emissions under Terminals licence – presented in
3/09-3 Circulate fuller version of the 2009 – 2012 EIP – completed and presented at the meeting for signing by community representatives if they so wish.
ITEM 3. EPA LICENCE REVIEW – ROUND TABLE DISCUSSION
George EPA have been suggesting that we ought to have a look at our licence limits. They want us to reduce our limits, there is an advantage to us if our limits are lower as we actually get a reduced licence fee. Going back to say 1999, 2000, 2001 and 2002, we were not complying with our EPA licence.
Robin Ethyl Acrylate was the main one
George Back then, Terminals accepted the then licence limits while not being in a position to comply. They were taken more as a target to aim for and there large improvements made. Terminals thought the EPA understood that we could not meet the limits set but when there were lots of complaints, Terminals was prosecuted by the EPA against itÕs licence. I learnt a great lesson. The facts are limits set by the EPA are not targets, limits are the limit. You need to have a limit that you can operate with.
Bro I agree with the philosophy you are outlining,
George The stack emission testing that is required to verify we are operating under our limits is done by contractors who attend the site and test for the range of chemicals that we store. The testing is done under the condition that present themselves on the day and this probably never at the maximum operating conditions (design conditions) as it would be very rare that we would have a ship berthed discharging down four lines at the same time into flammable tanks on a hot day where the tanks are breathing out as fast as they can which is the design case for the combustors. It is unlikely that we will test the combustor at that capacity.
Ian So the combustors are designed to cope with all this happening at once?
George Yes. We are normally operating well below, we are not a process plant. We did put some limits to Quentin and Quentin came back and said to justify them. We have calculated out a new set of limits as per the report.
Peter We do all these tests, Benzene, Acrylate during shipping under maximum pressure. The figures on the report are the results of this activity.
George You presume the bigger the vapour space the more the tank will exhale. Hot summer, pumping off a ship down all the docklines at the same time. That is the theoretical calculation and there are some conservatives in that. Factor of safety of 2 or 3 on the theory.
Quentin Licence is to be reviewed every 5 years. The EPA is in the process of doing this and has been going thru the process about a year ago. It was obvious to me that the licence is dated and some chemicals are no longer stored. Figures showed some conservatism. Frank Fleer EPA accredited auditor has created this list and some rationale with regards to limits set. The EPA is happy to have any thoughts at the meeting taken into account.
Robin Acrylonitrile and Propylene Oxide I cannot see why we have a proposed limit of Ō0Ķ and it needs to be taken out of the table.
Quentin If they are not stored they will not be on the licence.
George Will not be a line item on the licence
Robin That whole line should come out.
Faye On setting the limits are they set based on recommenced standards on health against a risk profile?
Quentin When limits were originally set any stack emissions had to comply with the ground level concentrations as specified in the State Environment Protection Policy (Air). Anything put through the combustor easily complies. The limits reflected best available health standards in 2011 it will be subject to review and that review work is done now and we might expect that some of those limits will be subject to reduction as new information becomes available over time with the World Health Organisation.
Faye So when a limit is passed is there a monetary $ amount related to exceeding the limit or do they then have to undergo further auditing.
Quentin These limits go into Terminals licence and they need to give a ŌStatement of ComplianceĶ each year to say they have achieved compliance. A non compliance can lead to enforcement action and fine to the magnitude of a quarter of a million dollars.
Faye What is the driver for change to keep them within the limits.
Quentin They are given a chance to get their act back together before they are jumped on. We hope that Terminals will be well below the limits and reduce further over time. We are reviewing performance over the past 5 years.
Ian Would it be fair comment to suggest that if there was relatively consistent non-compliance with a self administered licence, the EPA might consider going back to an EPA administered licence?
Quentin Well that is what we are doing at the moment we are reviewing their performance over the past 5 years and if we find those results are a cause for concern the accreditation will be withdrawn.
The major determinant of these limits is the hardware that has been built on site. While you have a licence the reality is what determines compliance is the facility that has been put into place. An improved facility was built a number of years back where a high efficiency extraction treatment system was put in place to collect and deal with these sorts of emissions. If you didnÕt have that as you can see in previous years there was difficulty complying with the limits.
George A range of Chemicals go through the combustor albeit the combustors were basically put there in the first place as they were the best available technology to handle Benzene. It is a bonus that we achieve much lower emissions for the other chemicals than is required by the SEPP.
Ian Have you done the cost benefit of it. How does the cost of running the combustor compare to the cost of the carbon beds.
George It is not that much more expensive. Everything is on the combustor now, with the carbon beds as a back up. The Combustor is not a huge gas user in comparison with other things like the site boilers. The gas bill at Coode is not dissimilar to heating Bitumen at Geelong.
Robin Another element to this as I understand it, some of the stuff was destroyed off site.
George The condensate from desorbing the carbon beds had to be carted away.
Ian Is there a possibility of using the heat generated from the combustor?
(See Items 7 & 8 below for further discussion on this matter.)
ACTION George will circulate the further calculations substantiating the proposed revised limits following the meeting, and will include reference to the SEPP limits.
Robin Confirmed that the view of the Committee was now to support the proposed limits.
ITEM 4. EIP 2009 – 2012: REVIEW OF EIP AND IAR
Robin EIP has been circulated and has been put on the website.
Robin Judging by the response around the table please advise Carlo he has done a magnificent effort on the table, very much appreciated.
Deborah Can we please pass onto Carlo our best wishes
Robin The CICCC wishes to express its best wishes to Carlo and his wife at this difficult time.
Deborah Very sad to hear of his wifeÕs illness and hope she makes a speedy recovery.
ITEM 5. REPORTS FROM AGENCIES AND TERMINALS
Robin Can we please concentrate on the incidents.
1. During an internal audit it was found that there had been a change in the rules and there was no up to date Hazardous Substances Register. This has since been incorporated into quality system.
Bro Can I ask how many previous audits were conducted prior to the issue being raised?
Deborah Worries me that the item was not picked up in previous audits.
George Sounds like it is a quality issue rather than a regularity issue. We never used to raise Unusual Occurrence Reports (UORÕs) for this type of incident whereas now we do. If we are finding the mistakes and doing something about them it is much better than doing nothing at all.
2. Foam deluge on the truck load gantry operated setting off the fire alarm. The shinny chrome work on the truck reflected light off tanker barrel which activated fire detectors.
This happens very occasionally and there is not much that can be done about it.
3. Whilst loading tanker product leaked from tanker manifold onto ground. The truck was banned until repaired and verified.
4. While a Terminals operator was cleaning the wharf line, his high visibility vest sleeve hooked onto the sample valve of Pacific Terminals line, which was being cleaned with steam, leading to a steam emission. The valve was an old type that could easily be knocked open. Luckily the steam did not burn the operator. Discussed with Pacific Terminals to update their valve. We have a good relationship with Pacific Terminals and they are replacing all valves on berth. Tool Box to remind operators to be careful. It is very congested with pipelines at the berth.
Robin Queried if the severity 1 of this incident was appropriate and George concurred with the query.
ACTION: George to talk to Geoff Millard regarding the severity rating of incidents.
5. Product found leaking from ship manifold valve prior to connecting hoses. The Odjell ship had this problem but the operators were wearing full protective gear anyway.
About 20 litres was spilt, and a meeting has been arranged with PoMC and the shipping company to discuss the incident.
George New tallow tank ready. One tank has received tallow the other ready and waiting for product.
Robin With regards to the ship incident, operators would never connect to a pipe that was leaking would they? Has that always been the case?
Pete Yes that has always been the case. The ship had to clean the spill up.
CITY OF MARYIBYRNONG
Theo sent an email to Robin regarding the Local Planning Application Updates and the ŌFootscray 150Ķ celebrations, which has been circulated.
ENVIRONMENT PROTECTION AUTHORITY
George There has been a report of a spill between Dynon Road and Footscray Road. There has been a sucker truck at the drain all week. It was reported on the news. Oil of some description, we think it has come from a truck yard.
Quentin The EPA did attend and investigate this matter. It was an oil slick on the Maribyrnong approximately 1,000 metres long, emanating from the Linfox site. There was a below ground tank flooding which led to the release into the Maribyrnong storm water system. This resulted in oil being educed from the river. The clean up is now complete.
Deborah Can I ask what flooding?
Quentin What I meant was that the tank containing the oil overflowed and released oil into the environment. Sounds like something went amiss leading to the tank overflowing.
George Was it sump oil or something?
Quentin It was black oil not sure.
Deborah I wouldnÕt mind knowing why it overflowed.
Quentin I think there will be further investigations
Robin If you get more details in the course of time Quentin please keep us informed.
Quentin New Client Relationship Manager for Terminals is Mark Cassanet who is responsible for both the Melbourne and Geelong sites, and will be located in the Melbourne office.
George How long has he been with the EPA?
Quentin 3 or 4 years, very capable. The Plan now is to get Mark up to speed and introduce him to CICCC. The role of Client Relationship Manager is not charged with policing anything as we have a separate enforcement area. The focus is on relationships with our clients
ITEM 6. Consideration of the Maintenance Planner
Peter The query last meeting was raised by Faye regarding the Maintenance Planner which is looked after by Col. All the things you see on the planner are governed by the Critical Controls Manual and Operations Manuals.
The Maintenance Manual and the Critical Control Performance Manual were circulated, and a table of maintenance items to be done during the year (the Maintenance Planner) was put on the screen
George The Critical Control Performance Manual is a manual that was created out of complying to the MHF legislation whatever banner it comes under nowadays and it is linked into our maintenance manual, most of it is regulatory requirements we need to do and also preventative maintenance requirements. The Maintenance Manual is in the process of being revamped at the moment and out of those is a whole list of things that we need to do. All our maintenance requirements come from these two manuals.
Peter As you can see from the planner, all as Col has to do is look at the planner and organize the maintenance contractor to come on site and complete the task. When the job is assigned, Col marks up the item in colour. Once the contactor has completed the task he marks off the job in another colour, enabling Col to readily see where he is up to with the maintenance. The tasks on the maintenance planner are governed by the Critical Control Performance Manual and the Maintenance Manual. There was an Unusual Occurrence Report raised last year as a check was missed. (see Item 5, Incident 1).
Col At the start of every month I look at that sheet and for every item on there it is either in the Critical Control Manual or Maintenance Manual. I then have to reflect the service schedule for that and issue to the operator and contractor the check sheets that are required to undertake the service, I highlight it in blue and when I get the information returned I highlight in yellow so that I can visually look at the planner and know that everything has been done.
George If you went into the manual the detail of how you actually do that check is in the manual as well.
Peter Work Safe spends a lot of time going overlooking at this Maintenance Planner when they audit us.
Ian I am presuming operational requirements as opposed to maintenance like checking the dipping of the tank is outside of this.
George That is not maintenance that is operational which forms part of our Operations Procedures Manual, which is Col is also responsible for.
Deborah Why are the Manuals marked confidential? Is this for security reasons?
George Cannot think of anything in there that would be confidential. The original document was set up many years ago and the cover has not been altered.
Robin Is there any question or further comment on the issue.
George In the end it is not a really complex thing. We have 2 levels:
1. In house checks that are performed by our operators, regulatory inspections that they might do such as inspecting the tank tops and bottoms, running fire pumps etc
2. Contractor checks where qualified contractors attend the site to perform calibration of instruments, checks on the vapour emission control systems, statutory checks for fire systems, all the sophisticated items.
These same checks operate at all our sites in a similar format.
Faye I was hoping there would be a computer program that would automatically update the Manuals to provide the Planner.
Robin It was your view that the use of the computer would make this more secure and safe?
Faye My view has not changed since five years ago.
Col I am quite confident with the manual system. The way it is now it is a visual system that I can see everyday. I highlight the action with one colour to indicate I have issued the check list to either an operator or contractor. Once the checklist is returned completed I use another colour highlighter to indicate the task is now complete. Using the highlighter system identifies what I have and have not done. If we had an automated or computerized system I would imagine a prompt would pop up on the screen and there would be nothing to stop me accepting that prompt and then forgetting to do it where as the visual system I can see what is yet to be completed and I think with the computer system I would spend a great deal of time maintaining the system as well.
Paul I have seen computerized maintenance systems in operations in much larger organizations which have many more staff. The system has to be tailored to that site and there is an enormous amount of information that has to be programmed into the system for it to work. But I have not seen a system yet that is simple enough and easy enough to suit our requirements like this system and this manual system works.
Col I think the other thing is the computerized system also has to have all the information put in to start with and the check list we missed could quite easily be missed on a computerized system if it wasnÕt programmed into it in the first place.
Faye One of the reasons this came to be an issue was that one of the checks did slip through the cracks so that not all things are caught by the system. If you have to reprioritize the list every time something comes into the list it is very difficult to do a check. It is so much better to be proactive rather than reactive. Computerized systems would highlight efficiency factors.
Col The services are not prioritized they all have to be done very month.
Faye What happens if you go off site.
Col The contractors or anyone else can look at the planner and see what checks they have to do.
Faye But you are still reactive instead of proactive.
George The checks are all in the manuals and it is a matter of making sure they are done. All in house checks and contractor checks are mirrored in the manuals. Associated with this is a separate system for maintenance requests, it is not a breakdown manual.
Faye So this is not linked to any other set of maintenance requirements that have to be done first. In my opinion it is very clumsy and just waiting for something to happen with safety.
George The fact is that particular check in question wasnÕt done and was picked up by audits. If you have a computer system you then have to get a computer programmer to come and put the check in the computer also.
Robin There are two views here:
Faye – that a computer system would be intrinsically fail safe
Terminals – not true as the one that was missed was a human error and that the same human error might well have happened with a computer system. The maintenance planner is a visual planner that works well.
George When WorkSafe come on site they go to the Critical Control Manual, open it up and look at the particular checks and then ask for Terminals to demonstrate to them that they have been done. Col then retrieves the relevant report completed by the contractor. Now in a computer program just because it is ticked off on a computer doesnÕt count as the computer would only be a glorified maintenance planner.
Faye Not proactive and not particularly safe.
Robin Faye has raised an issue and we have given attention to the issue and you have had a couple of discussions and what I am hearing is that Terminals are perfectly happy with the maintenance planner and I am not sure we can take this much further.
Ian I am also a member of a group known as the Asset Management Council and if you were to attend those meetings you will keep absolutely up to date with whatever maintenance systems that are around.
Faye You can link in a risk management system.
George We only have a limited maintenance budget. Two thirds of that maintenance budget is taken up with scheduled maintenance systems already in place. The fire systems, the statutory checks required on those are certainly proactive. This is to make sure the equipment is kept pristine. We are not licenced to undertake those checks ourselves, they are carried out by qualified contractors.
Faye What you are saying is that all the events that come under the maintenance schedule if they were to fail, the consequence of the failure of those checks will be dealt with on a day to day basis and are not going to be a health or safety issue. Is that what I am hearing?
George On the whole there would be a small handful of things that would fall into the category that you are talking about.
Faye Then I have to accept that
Ian It really depends on the complexity of whatever goes wrong.
Robin I might draw that discussion to a close if that is alright with everyone.
ITEM 7. Preheating Liquid Injection to Combustors
Paul Terminals asked the EPA for permission to burn combustible waste with a flash point above 60oC. The EPA want us to do some sort of greenhouse gas trade off. Wastes are usually a mixture of water and contaminants.
Paul then explained the drawing of the Liquid Waste Pre-Heater system.
Deborah How much are you proposing to burn off each year?
Paul 700 tonnes
George We are trying to save greenhouse gases by taking on this approach as less gas is being used.
Robin What is being done with the waste at present?
Peter The waste is being sent to Transpacific who separate the solid, water and hydrocarbons.
Bro I had raised in the past Co-generation opportunities - pleased to see this, it is a good move.
George It is early days we have just received the proposal back from the designers.
Quentin As a concept it appears good
George The other benefit that the flammable waste will go thru this preheating as well increasing itÕs flammability. Our waste mixes change. Waste goes thru the combustor at 3 litres a minute which is not a major injection into the combustor.
Deborah Is there any toxic by-products from those being burnt?
George No caustic products will be put through the system, so the production of dioxins and furons will be avoided.
Paul The proposal is to add combustible waste to flammable waste already treated in combustor. Combustor can handle 6 litres per minute which over a 10 hour day (6am to 4pm) 5 days a week equals 930 tonnes per year. Therefore capacity to handle flammable and combustible waste in normal hours. One combustor is always off.
Quentin It would be desirable to show that the proposal is greenhouse neutral. Expects further information from Terminals in due course.
ITEM 8 Combustor Low Fire at Night
Paul At night tanks do not breathe so there is no flow of vapour through the combustors but a combustor will continue to run maintaining 750 Degrees. We are proposing to install the capacity for the combustors to turn right down to a very low operation, almost like a pilot light, so they can automatically fire up if tank pressures start to increase ready to receive vapours.
Deborah What is the normal combustor start up time.
Paul Normal start up time is 10 to 15 minutes. The pilot light will make starting the combustor quicker. When starting up from cold we have experienced a few problems. This light actually keeps it in a state of operation and keeps the temperature just warm. It will save energy and greenhouse gasses.
Quentin Sort of like a hot standby
ITEM 9. Other Business
NEXT SCHEDULED MEETINGS:
Meeting dates for 2009 – 10th September, 2009 and 10 December, 2009
MEETING CLOSED 9:00 PM