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Annual Performance Statement

Calender Year 2010

XYZ GAS REFINING


Holder of

Licence: G23456
Issued: 20 September 1976
Last Amended : 6 June 2010
ACN: 12345678910
ABN: 11121314151
Registered address: 123 Smith St
SYDNEY NSW 2233
Premises address: XYZ Refinery
Refinery Rd
MULGOWA VIC 3333

Licence activities: G23456 (XYZ GAS REFINING) is scheduled by the


Regulations as G03 – Oil and Gas Refining

STATEMENT OF COMPLIANCE
Analysis of performance against Environmental Performance Conditions

Condition Conditio Condition Description Conditi


Area n on
Referen Compli
ce ed
with?
Amenity A1 Offensive odours must not be discharged
Yes
beyond the boundaries of the premises.
Amenity A2 Unacceptable noise (including vibration)
must not be emitted beyond the boundaries Yes
of the premises
Discharges DA1 Discharge of waste to air must be in
No
to air accordance with the 'Discharge to Air' Table
Discharges DA2 Visible emissions to air other than steam
No
to air must not be discharged from the premises.
Discharges DW1 Stormwater discharged from the premises
No
to water must not be contaminated with waste.
Discharges DW2 Discharge of waste to surface waters must
to water be in accordance with the 'Discharge to No
Water' Table.
Discharge to DL1 You must not contaminate land or
land groundwater. No

General G1 Waste from the premises must not be No


conditions discharged to the environment except in
accordance
with this licence.
General G2 You must immediately notify EPA of non-
conditions compliance with any condition of this No
licence.
General G3 By 30 September each year you must
conditions submit an annual performance statement
to EPA for the
previous financial year in accordance with
Yes
the Annual performance statement
guidelines (EPA
Publication 1320).

General G4 Documents and monitoring records used for


conditions preparation of the annual performance
statement
Yes
must be retained at the premises for seven
years from the date of each statement.

General G5 You must implement a monitoring program


conditions that enables you and EPA to determine Yes
compliance with this licence

I, ......................................, declare that the information in this Annual Performance


Statement is true and correct. I have made all the necessary enquiries, and no
matters of significance have been withheld from EPA.¹

Name: ......................................

Position:..........................................................................Signature:..............................
.......................................

Date:

1. Under Section 31D(5) of the Environment Protection Act 1970, it is an offence to provide false or
misleading information in an annual performance statement or conceal any relevant information or
document from the Authority. Contravention of subsection (5) is an indictable offence that carries a
penalty of 2400 penalty units or imprisonment for two years, or both.
ATTACHMENT A

Details of Non-Compliance with Licence


Condition
DA1. Discharge of waste to air must be in accordance with the
'Discharge to Air' Table.

________________________________________________________________________________________
a) Date(s) when the non-compliance occurred (if applicable)

3-March-2009
________________________________________________________________________________________
b) Summary of particulars of non-compliance

Elevated rate of 25 mg/min NO2 emission was detected


________________________________________________________________________________________
c) What is your assessment of environmental impact as a result of non-compliance

Acid rain, climate change, smog


________________________________________________________________________________________
d) Cause of non-compliance

The thermal oxidiser's burner management system was unable to readjust the
fuel/air requirement to maintain a clean burn after a part of processing flow being
redirected during a process upset and altered the flow through thermal oxidiser.
________________________________________________________________________________________
e) Action taken or that will be taken to mitigate any adverse effects of the non-
compliance

The plant was shut down and EPA were notified.


________________________________________________________________________________________
f) Action taken or that will be taken to prevent recurrence of the non-compliance

The process of redirecting the flow from the thermal oxidiser was assessed and fine-
tuned by engineers to allow burner management system time to adjust and prevent
off-specification emissions if a similar process upset occurred. An alarm system was
also added to alert operations immediately of the process upset.
ATTACHMENT A

Details of Non-Compliance with Licence


Condition
DA2.Visible emissions to air other than steam must not be
discharged from the premises.

_____________________________________________________________________________________
a) Date(s) when the non-compliance occurred (if applicable)

3-March-2009
_____________________________________________________________________________________
b) Summary of particulars of non-compliance

Visible emissions of NOx were discharged from the factory.


_____________________________________________________________________________________
c) What is your assessment of environmental impact as a result of non-compliance

Air pollution in the form of acid rain and visibility impairment


_____________________________________________________________________________________
d) Cause of non-compliance

Failure of the thermal oxidiser’s burner to readjust fuel and air requirement for clean
burn resulting in the emissions of NOx gas to the environment
_____________________________________________________________________________________
e) Action taken or that will be taken to mitigate any adverse effects of the non-
compliance

The plant was shut down and the thermal oxidiser’s burner was tuned in order to
prevent such off-specification to happen again.
_____________________________________________________________________________________
f) Action taken or that will be taken to prevent recurrence of the non-compliance

An alarm system was installed so that the operators will be notified immediately
when an off-specification happens again.
ATTACHMENT A

Details of Non-Compliance with Licence


Condition
DW1. Stormwater discharged from the premises must not be
contaminated with waste.

_____________________________________________________________________________________
a) Date(s) when the non-compliance occurred (if applicable)

4-August-2009
_____________________________________________________________________________________
b) Summary of particulars of non-compliance

Spillage of more than 10 tonnes of synthetic lubricant which covered an area of


about 30m2. This resulted in the flow of the lubricant into the run-off water system
_____________________________________________________________________________________
c) What is your assessment of environmental impact as a result of non-compliance

High BOD level in stormwater and possible eutrophication in areas of still waters.
_____________________________________________________________________________________
d) Cause of non-compliance

Bund plug of the vessel storing the synthetic lubricant was not in place and
improper containment of spillage
_____________________________________________________________________________________
e) Action taken or that will be taken to mitigate any adverse effects of the non-
compliance

Hot water was used to flush the run-off water drain


_____________________________________________________________________________________
f) Action taken or that will be taken to prevent recurrence of the non-compliance

A chemical skid is being installed around the storage vessel to prevent future
spillages from flowing into the run-off water system
ATTACHMENT A

Details of Non-Compliance with Licence


Condition
DW2. Discharge of waste to surface waters must be in accordance
with the 'Discharge to Water' Table.

_____________________________________________________________________________________
a) Date(s) when the non-compliance occurred (if applicable)

4-August-2009
_____________________________________________________________________________________
b) Summary of particulars of non-compliance

Water temperature increased to 36°C which exceeded 35°C, total organic carbon
content raised to 14mg/L and 11mg/L correspondingly exceeded limit of 10mg/L and
BTEX level reached 1.2mg/L which exceeded 0.7mg/L due to spillage of synthetic
lubricants and clean up using hot water.
_____________________________________________________________________________________
c) What is your assessment of environmental impact as a result of non-compliance

Photochemical smog, toxic to aquatic life and damaging the crops due to excess
BTEX. The depletion of dissolved oxygen in water due to high temperature.
_____________________________________________________________________________________
d) Cause of non-compliance

Spillage of synthetic lubricants, hot washing water was used to clean the spillage
which then caused the increase in water temperature to 36°C when the water was
to discharge to the run-off water stream
_____________________________________________________________________________________
e) Action taken or that will be taken to mitigate any adverse effects of the non-
compliance

The site washed the spillage with hot water. Shoreline was suggested to be used in
cleaning the spillage.
_____________________________________________________________________________________
f) Action taken or that will be taken to prevent recurrence of the non-compliance

Signs of any leakages from the glands, seals, gaskets or any other parts of the
system are to be checked by using alarming system. Tightness of all the piping
system that involved in the refining operation is to be checked. A supervisor is
required to be familiar with all the processes that are going on in the site to prevent
careless incident to take place.
ATTACHMENT A

Details of Non-Compliance with Licence


Condition
DL1. You must not contaminate land or groundwater.
_____________________________________________________________________________________
a) Date(s) when the non-compliance occurred (if applicable)

4-August-2009
_____________________________________________________________________________________
b) Summary of particulars of non-compliance

Spillage of 10 tonnes of synthetic lubricant and poor containment of the material


after the spillage, causing it to cover an area of 30m2

____________________________________________________________________________________
c) What is your assessment of environmental impact as a result of non-compliance

Spilt lubricant and portion of the off-specification waste water may have leached
through the ground and contaminate the soil and groundwater. This causes pollution
to soil and groundwater as well as the formation of ground level ozone which can
damage crops and materials.
_____________________________________________________________________________________
d) Cause of non-compliance

Dislocations of the lubricant vessel bund plug which resulted in the spillage, which
was not properly contained and removed.

_____________________________________________________________________________________
e) Action taken or that will be taken to mitigate any adverse effects of the non-
compliance

Material was flushed to the run-off water system with hot water.
_____________________________________________________________________________________
f) Action taken or that will be taken to prevent recurrence of the non-compliance

Develop management procedures to contain and collect spills, including practical


steps to prevent discharge of split material through the licenced waste water
emission point. Construct containment and maintained vessels for any potential
contaminating material. Retrain operators on handling emergency spillage according
to appropriate procedure.
ATTACHMENT A

Details of Non-Compliance with Licence


Condition
G1. Waste from premises must not be discharged to the
environment except in accordance with this license.

_____________________________________________________________________________________
a) Date(s) when the non-compliance occurred (if applicable)

5-May-2009
_____________________________________________________________________________________
b) Summary of particulars of non-compliance

Discharge of unlicensed building material to the environment


_____________________________________________________________________________________
c) What is your assessment of environmental impact as a result of non-compliance

Potential harm to human health and unwanted odours


_____________________________________________________________________________________
d) Cause of non-compliance

A building material was being blown offsite from a part of the site undergoing
maintenance work.
_____________________________________________________________________________________
e) Action taken or that will be taken to mitigate any adverse effects of the non-
compliance

Nil
_____________________________________________________________________________________
f) Action taken or that will be taken to prevent recurrence of the non-compliance

Appropriate storage and handling of building materials should be taken into


consideration for the compliance of the licence. A protection barrier is to be installed
at the site boundary to prevent material from being blown offsite.
ATTACHMENT A

Details of Non-Compliance with Licence


Condition
G2. You must immediately notify EPA of non-compliance with any
condition of this license.

_____________________________________________________________________________________
a) Date(s) when the non-compliance occurred (if applicable)

4-August-2009 & 5-August-2009


_____________________________________________________________________________________
b) Summary of particulars of non-compliance

EPA was not notified regarding the spillage of 10 tonnes of synthetic lubricant until
after the spill had been flushed into the run-off water drain.
_____________________________________________________________________________________
c) What is your assessment of environmental impact as a result of non-compliance

This will result in improper handling of the non-compliance condition without


professional advice and immediate corrective action. Contaminants might have
been released into the environment and caused pollution.
_____________________________________________________________________________________
d) Cause of non-compliance

The site Environment Manager was not notified until after the spill had been flushed
to the run-off water system.
_____________________________________________________________________________________
e) Action taken or that will be taken to mitigate any adverse effects of the non-
compliance

Nil
_____________________________________________________________________________________
f) Action taken or that will be taken to prevent recurrence of the non-compliance

Develop a reporting procedure for emergency situations so that the Environmental


Manager is notified immediately if there is any emergency spillage. The
Environmental Manager is then obliged to notify the EPA of the emergency.
ATTACHMENT B
Additional Information
AIR

a) Summary of statistics for discharge limits

Table B-1.1 Licensed discharge limits for air emissions.


Discharge Point Indicator Units Limit Type Amou
nt
Thermal Oxidiser Vent
NO2 discharge rate g/min Maximum 20
(DP1)
Thermal Oxidiser Vent
SO2 discharge rate g/min Maximum 150
(DP1)
Thermal Oxidiser Vent
H2S discharge rate g/min Maximum 0.05
(DP1)
Thermal Oxidiser Vent Toluene discharge
g/min Maximum 0.0002
(DP1) rate
Thermal Oxidiser Vent Benzene discharge
g/min Maximum 0.0002
(DP1) rate

b) Number of samples taken and periods of sampling

Parameters such as NO2, SO2 and H2S are monitored in a daily basis producing a
total of 365 samples, whereas Toluene and benzene are monitored in monthly
basis producing a total of 12 samples over the reporting year 2009.

Table B-1.2 Sampling period and number of samples taken for each
indicator.
Indicator Units No. of samples Periods of
taken sampling
NO2 g/min 365 Daily
SO2 g/min 365 Daily
H 2S g/min 12 Monthly
Toluene g/min 12 Monthly
Benzene g/min 12 Monthly

c) Quarterly discharge rates.

Summary of the discharge rates over the reporting year of 2009 is tabulated in
Table B-1.3. Breach of the air discharged point licence occurred at 3-March-2009
where emission of NO2 exceeded the licence limit. Refer to Attachment A for
details.

Table B-1.3 Quarterly discharge rates for each indicator.


NO2 SO2 H2S Toluene Benzene
Period
(g/min) (g/min) (g/min) (g/min) (g/min)
1/1/2009 to 31/3/2009 14.967 123.078 0.003 0.000083 0.000083

1/4/2009 to 30/6/2009 15.066 123.736 0.003 0.000067 0.000083

1/7/2009 to 30/9/2009 14.902 121.576 0.006 0.000083 0.000067


1/10/2009 to
14.815 120.196 0.012 0.000075 0.000075
31/12/2009
WATER

a) Summary of statistics for discharge limits

Table B-2.1 Licensed discharge limits for water discharges.


Amou
Discharge Point Indicator Units Limit Type
nt
Water Discharge Point - Total organic carbon
mg/L Maximum 10
Refinerville Bay discharge limit
Total residual
Water Discharge Point -
chlorine discharge mg/L Maximum 0.1
Refinerville Bay
limit
Water Discharge Point - Oil and grease
mg/L Maximum 5
Refinerville Bay discharge limit
Water Discharge Point - Suspended solids Annual
mg/L 5
Refinerville Bay discharge limit Median
Water Discharge Point -
BTEX discharge limit mg/L Maximum 0.7
Refinerville Bay
Water Discharge Point - Copper discharge
mg/L Maximum 0.1
Refinerville Bay limit
Water Discharge Point -
Zinc discharge limit mg/L Maximum 0.5
Refinerville Bay
Water Discharge Point - Nickel discharge
mg/L Maximum 0.2
Refinerville Bay limit
Water Discharge Point - Dissolved oxygen
mg/L Minimum 5
Refinerville Bay discharge limit
Water Discharge Point -
Temperature °C Maximum 35
Refinerville Bay

a) Number of samples taken and periods of sampling

Parameters total organic carbon is monitored daily, total residue chlorine, oil and
grease and temperature are monitored weekly; BTEX, copper, zinc and nickel is
monitored on monthly basis producing 365, 52 and 12 samples over the reporting
year respectively.

Table B-2.2 Sampling period and number of samples taken for each
indicator.
No. of samples Periods of
Indicator Units
taken sampling
Total Organic
mg/L 365 Daily
Carbon
Total Residue
mg/L 52 Weekly
Chlorine
Oil and Grease mg/L 52 Weekly
Suspended solids mg/L 12 Monthly
BTEX mg/L 12 Monthly
Copper mg/L 12 Monthly
Zinc mg/L 12 Monthly
Nickel mg/L 12 Monthly
Dissolved Oxygen mg/L 12 Monthly
Temperature ᵒC 52 Weekly

b) Quarterly discharge rates.

Summary of the discharge rates over the reporting year of 2009 is tabulated in Table
B-2.3. Breach of the water discharged point licence occurred on 4 and 5-August-2009
where indicators such as total organic carbon, temperature and BTEX exceeded the
licence limits. Refer to Attachment A for details.

Table B-2.3 Quarterly discharge rates for each indicator.


Total Total Suspen
Oil and Temperat
Organic Residue ded
Period Grease ure
Carbon Chlorine Solids
(mg/L) (ᵒC)
(mg/L) (mg/L) (mg/L)
1/1/2009 to 31/3/2009 2.467 <0.047 <1.538 28.692 5.000

1/4/2009 to 30/6/2009 2.703 <0.037 <1.215 22.231 4.333

1/7/2009 to 30/9/2009 2.859 <0.035 <1.000 23.154 2.333

1/10/2009 to 31/12/2009 2.087 <0.031 <1.000 26.000 3.033


Dissolve
BTEX Copper Nickel Zinc d
Period
(mg/L) (mg/L) (mg/L) (mg/L) Oxygen
(mg/L)
1/1/2009 to 31/3/2009 <0.006 0.007 0.008 0.009 7.167

1/4/2009 to 30/6/2009 <0.006 <0.003 <0.002 <0.005 7.333

1/7/2009 to 30/9/2009 <0.395 <0.004 <0.002 <0.009 7.600

1/10/2009 to 31/12/2009 <0.006 0.003 <0.003 <0.011 7.133


ATTACHMENT C
Sustainability Commitment
Waste Water Treatment

Currently, waste water is discharged to the adjacent marine environment without


proper treatment.

The water discharge contains organic substance that might cause eutrophication
and might increase BOD level by encouraging the growth of bacteria in marine
environment.

It is recommended that the process waste water undergo an anaerobic treatment


before discharging to the environment. This anaerobic treatment could reduce the
amount of BTEX, suspended solids, total organic carbon as well as decrease the BOD
level in the waste water discharge. The suggested anaerobic treatment is a UASB
reactor. This type of reactor has proof to be effective in research as well as practical
usage. The methane captured could be burned to provide energy to the plant.

Heavy metals (Ni, Zn and Cu) in the discharge would pose health hazard to human
and aquatic life. It is known that heavy metal causes human toxicity and aqua-
toxicity. The heavy metals in the discharge waste water could be removed through
Ion Exchange Extraction of Heavy Metals.

Oil and grease present in the waste water stream could cause aqua-toxicity, it is
recommended to remove it through a skimmer before treating it with anaerobic
treatment.

The discharge also contains residual heat from the process and change the
ecological system in the marine environment. It is recommended to have continuous
monitoring system for the temperature of the discharge stream. If there is a rise in
the discharge temperature, immediate actions need to be taken to prevent
excessive heat discharged.

Plant management

The plant management team should be provided with the essential resources on the
implementation and the control of the environmental management system. These
resources included training, human resources, specialty services, financial
resources, technical and informational services. The employees should also be
trained at each level and to the relevant environmental function so that they are
aware of the significance of their role and responsibilities on environmental aspects
and impacts. If possible, trainers are advised to keep records of employees during
the training to assure appropriate monitoring.

Plant management team should implement and operate the plant in best usage of
energy. This will lead to the decreased of emission due to the increased of efficiency
of energy. Checking and maintenance of all the plant equipment should be done
from time to time to ensure the plant to operate properly and achieve highest
efficiency of processes. Nevertheless, commitment of the plant management team
is crucial in order to keep the plant operating in the best status.
Scrubber System (SOx and NOx)

Advantages:

- Remove pollution from smokestacks and exhaust systems, keeps harmful


chemicals and fumes from entering the atmosphere

- some designed to capture gases and solid particles

- air pollution control helps reduces carbon and emissions (reduce ozone depletion
and global warming)

Dry Scrubbing

Dry scrubbing system does not saturate the flue gas stream which is treated by
moisture. It is used to remove acid gases from the feed stream in the combustion stage.
Different type of scrubbing system are available however, all consist of two main
sections or devices which is a device to introduce the acid gas sorbent material into the
gas stream and a particulate matter control device to remove reaction products, excess
sorbent material as well as any particulate matter already in the flue gas.

Dry scrubbing systems can be categorized as dry sorbent injectors (DSIs) or as spray
dryer absorbers (SDAs). Spray dryer absorbers are also called semi-dry scrubbers or
spray dryers. Dry scrubbing systems are often used to remove odorous and corrosive
gases from wastewater treatment plant operations. The media used is typically an
activated alumina compound impregnated with materials to handle specific gases such
as hydrogen sulfide.

Dry sorbent injection:

Addition of an alkaline material (hydrated lime or soda ash) into the gas stream to react
with the acid gases. Sorbent can be inject directly into different location such as the
combustion process, flu gas duct or open reaction chamber if exist. The acid gases react
with the alkaline sorbents to form solid salts which are removed in the particulate
control device. These simple systems can achieve only limited acid gas (SO 2 and HCl)
removal efficiencies. Higher collection efficiencies can be achieved by increasing the
flue gas. These devices have been used on medical waste incinerators and a few
municipal waste combustors.

In spray dryer absorbers:

The flue gases are introduced into an absorbing tower (dryer) where the gases are
contacted with a finely atomized alkaline slurry. Acid gases are absorbed by the slurry
mixture and react to form solid salts which are removed by the particulate control
device. The heat of the flue gas is used to evaporate all the water droplets, leaving a
non-saturated flue gas to exit the absorber tower. Spray dryers are capable of achieving
high (>80%) acid gas removal efficiencies. These devices have been used on industrial
and utility boilers and municipal waste incinerators.

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