COODE ISLAND COMMUNITY
Adopted Minutes Special Meeting
Thursday 06 May 2004
CICCC / Chairperson
Managing Director, Terminals Pty Ltd
Community Rep. / CICCC Committee
State Manager, Terminals Pty Ltd
Operations Manager, Terminals Pty Ltd
Env. Protection Authority / Ex Off Comm
Bronwyn Brookman Smith:
MH Div / WorkSafe/Ex Off Com
Manager, Emergency Mgmt, City of Marb’
ITEM 1. WELCOME BY THE CHAIR
Robin Welcomed everyone
ITEM 2. APOLOGIES
Chris Watts, Colleen Hartland, Margaret Donnan,
ITEM 3. CONFIRMATION OF DRAFT AGENDA
ITEM 4. TERMINALS PRESENTATION FOR PHENOL STORAGE
(Presented by Peter LaRose)
Please refer Phenol Storage Attachment
Huntsman Chemical Company is planning to cease production of phenol at their Brooklyn plant, from which they presently supply the local market (including their own requirements) of about 12,000 tonnes per year. They will change from being a small exporter of excess production to being a significant importer. Huntsman has given Terminals a letter of understanding, and details of requirements and approval processes are now being worked through.
Terminals are already licensed to import and export phenol, and have two heated phenol tanks in the Plant C East, only one of which is in use.
The proposed new site for the two relocated and upgraded phenol tanks is the south west corner of Plant B West. The tanks will have HDPE under-liners (probably on concrete bases), and sealed bund floors. They will have a completely sealed system, including a new, bigger-volume caustic scrubber. The new scrubber will be 99% efficient, compared to the existing scrubber which is 95% efficient. The new road tanker loading bay will have a sealed tank vapour return system. The cost of establishing the facility is anticipated to be $1.7 to $1.8 million.
Wastes from tank cleaning, line pigging and scrubbing will be disposed of to licensed waste premises, and it is possible that Huntsman will take them to dispose of in their biological treatment facility.
ACTION: Terminals to report back how waste product will be dealt with and to which licensed treatment facilities will the wastes be sent?
Questions: If there is a spill where does it go?
Into the Bund, tanks will be fully bunded.
What other chemicals are close by that could react with Phenol?
The tanks are purpose built, and the only chemical that reacts with it is butadiene & butadiene is not stored at Melbourne.
What are the Safety Risks?
It is a local risk not an off-site risk. It is not flammable but it is toxic if swallowed and will burn the skin if in contact
ITEM 5. EPA OUTLINE OF APPROVAL PROCESS
(Presented by Quentin Cook)
Quentin listed some other accredited licensees, including Mobil Refinery, Qenos and BASF.
Although a facility such as is being proposed for a new material with new technology would normally need a Works Approval, as Terminals is an accredited licensee, Works Approval is unlikely to be required. Terminals must now submit a notification to EPA, setting out reasons why it doesn’t need Works Approval.
ACTION: Quentin to report whether there are any examples of when an Accredited Licensed premises needed a works approval by next meeting.
ACTION: George to supply a copy of the submission to the EPA for Phenol Storage.
Terminals have received their accreditation 06.04.05. This means that they can proceed with certain works without a works approval. To do this there is a process where Terminals will provide the EPA with a letter & documentation outlining why Terminals believes that a works approval is not required.
Ian: In terms of the granting of accreditation, how do companies eg: Mobil, get away with sulphur odours?
Quentin: EPA have looked into it and it is not Sulphur it is the bitumen plant & the Water Treatment Plant. The company is asked to redress the problem & must show better endeavours to improve otherwise the process begins of review & withdrawal of accreditation that may include later prosecution.
Faye: How many violations must there be before an Accreditation is withdrawn?
Quentin: It depends on whether the company is using its best endeavours to resolve the problem. If it is not, then the accreditation may be ultimately withdrawn.
George: An Accredited Licence is a rigor. The licence means we must demonstrate that our practices are up to standard. We are continually audited & checked by our EPA accredited auditor. It is in our EIP & Environmental Manuals.
Robin: Perhaps at some point the EPA Auditor could do a presentation on the process of these demonstrations of compliance.
In response to a comment that standards could slip under an accredited licence - To put this back to the beginning back in 1998 there was no long term tenure and the EPA were fed up with Terminals because of the emissions of odours. It was apparent that money was urgently need to upgrade the system. There were various penalties at that time with prosecutions, Pin notices & the threat of $120,000 per day daily fines for continual emissions of odours.
Terminals took action by removing Benzene & making the Acrylate users accountable for their chemicals. With this action and subsequent upgrade Terminals were able to facilitate improvements to the facility which underpin the current high level performance. Terminals will not return to the problem it had in the past.
Robin: Will the EPA take firm action with Accredited Licensees?
Quentin: The expectation that Licensees will continue to improve & that they demonstrate this. They are expected to maintain this capacity & their commitment. The companies are required to submit an annual report, and Accreditation is reviewed every 5 years.
Michael: How is it determined when a Works Approval is required & what is required from the company?
Quentin: The company details its proposals in a scope document to the EPA. The EPA then looks at what the existing Licence covers, and whether it needs to be amended. A company with an Accredited Licence is aware of the obligations to have the works properly completed. The works approval requirement by the EPA is based on these factors.
Robin: In summary: An Accredited Licence is granted, further works are submitted via a scope document, the EPA then determines whether approval is required, if it is not then it is managed through Quality Audit Systems.
Robin: The Committee would like all communications tabled at the meeting with regard to the Phenol submissions.
Robin: Government has confirmed that they will continue to control planning permits for the ports.
Robin: Do Terminals plan to be upfront with Phenol.
Robin: Suggest a Media Release and an invitation to the media & community for a representative of Terminals be available to discuss this further, so the situation is transparent.
Michael: It is possible to argue that this new system is safer than the old one and that Terminals is moving in the right direction.
Robin: Will this get into Terminals EIP?
Quentin: The current is due for renewal – would appear in that
Robin: Could then appear in the Current Improvement Action Report.
Quentin: Would be appropriate & EPA would require this.
PUBLICITY: Discussion was held as to how to inform the public. Given this is a “low hazard” material, it was thought that the media release highlight the next Phenol project meeting and that would be appropriate.
ITEM 6: WORKSAFE
(Presented by Bronwyn Brookman-Smith)
§ Phenol already covered, not new to the site
§ Terminals have been required to review the Risk Assessment
§ Advised that HAZOP Workshops will have to be done
§ Revisions to be forwarded to Worksafe
§ Can introduce the tanks because the existing Licence includes phenol storage
§ Terminals have been advised that Worksafe will be present at construction
§ Under the Dangerous Goods Legislation Terminals is required to get written authority from Fire Authority
§ New activities on site
§ New location
§ New conditions to storage
Theo: From a planning point of view, could Terminals inform the council when the application is lodged.
ACTION: George to notify council when the planning application is submitted & a copy of the planning application will be supplied to council (and to CICCC).
ITEM 7: QUESTIONS & DISCUSSION
Robin: Committee has invited Mr Stensholt MP to the next meeting, and he has accepted.
Robin: Death of EPA Past Chairman Brian Robinson acknowledged.
George: Committee asked to look at what has been presented and if they have any queries or suggestions, or would like anything clarified please email these to firstname.lastname@example.org
Robin: Confirmation that next special meeting will take place on 10 June 04, followed by the next scheduled meeting on 15 July 2004.
Meeting Closed 8.20pm