18th June, 2009
CICCC / Chairperson
General Manager, Terminals
Community Rep./Committee Member
Peter La Rose
Community Rep./Committee Member
Community Rep./Committee Member
ITEM 1. WELCOME
BY THE CHAIR, APOLOGIES & CONFIRMATION OF DRAFT AGENDA
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
of draft agenda – adopted
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
don’t 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.
cannot remember what happened previously when we set up the first EIP
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.
do not understand the rationale for signing this at all.
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
EPA’s 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.
ought to take this up with Quentin when he gets here as I thought the EPA was
backing away from actually signing the EIP’s now and I don’t 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
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
Minutes of the 12th March, 2009 adopted without change.
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
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
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
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 it’s 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.
agree with the philosophy you are outlining,
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.
the combustors are designed to cope with all this happening at once?
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.
do all these tests, Benzene, Acrylate during shipping under maximum pressure.
The figures on the report are the results of this activity.
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.
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.
and Propylene Oxide I cannot see why we have a proposed limit of “0” 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
Robin That whole line
should come out.
setting the limits are they set based on recommenced standards on health against
a risk profile?
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.
when a limit is passed is there a monetary $ amount related to exceeding the
limit or do they then have to undergo further auditing.
limits go into Terminals licence and they need to give a “Statement of
Compliance” 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
Faye What is
the driver for change to keep them within the limits.
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.
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
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.
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 didn’t have
that as you can see in previous years there was difficulty complying with the
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.
you done the cost benefit of it. How does the cost of running the combustor
compare to the cost of the carbon beds.
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.
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.
there a possibility of using the heat generated from the combustor?
Items 7 & 8 below for further discussion on this matter.)
will circulate the further calculations substantiating the proposed revised
limits following the meeting, and will include reference to the SEPP limits.
that the view of the Committee was now to support the proposed limits.
ITEM 4. EIP
2009 – 2012: REVIEW OF EIP AND IAR
has been circulated and has been put on the website.
by the response around the table please advise Carlo he has done a magnificent
effort on the table, very much appreciated.
we please pass onto Carlo our best wishes
CICCC wishes to express its best wishes to Carlo and his wife at this difficult
sad to hear of his wife’s illness and hope she makes a speedy recovery.
ITEM 5. REPORTS
FROM AGENCIES AND TERMINALS
we please concentrate on the incidents.
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.
I ask how many previous audits were conducted prior to the issue being raised?
me that the item was not picked up in previous audits.
like it is a quality issue rather than a regularity issue. We never used to
raise Unusual Occurrence Reports (UOR’s) 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.
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.
happens very occasionally and there is not much that can be done about it.
loading tanker product leaked from tanker manifold onto ground. The truck was
banned until repaired and verified.
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
if the severity 1 of this incident was appropriate and George concurred with
ACTION: George to talk
to Geoff Millard regarding the severity rating of incidents.
found leaking from ship manifold valve prior to connecting hoses. The Odjell
ship had this problem but the operators were wearing full protective gear
20 litres was spilt, and a meeting has been arranged with PoMC and the shipping
company to discuss the incident.
tallow tank ready. One tank has received tallow the other ready and waiting
regards to the ship incident, operators would never connect to a pipe that was
leaking would they? Has that always been the case?
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 “Footscray
150” celebrations, which has been circulated.
ENVIRONMENT PROTECTION AUTHORITY
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.
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?
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
George Was it sump oil or something?
Quentin It was black oil not sure.
Deborah I wouldn’t mind knowing why it overflowed.
Quentin I think there will be further
Robin If you get more
details in the course of time Quentin please keep us informed.
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
long has he been with the EPA?
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
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.
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
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.
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).
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.
you went into the manual the detail of how you actually do that check is in the
manual as well.
Safe spends a lot of time going overlooking at this Maintenance Planner when
they audit us.
am presuming operational requirements as opposed to maintenance like checking
the dipping of the tank is outside of this.
is not maintenance that is operational which forms part of our Operations
Procedures Manual, which is Col is also responsible for.
are the Manuals marked confidential? Is this for security reasons?
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:
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
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.
same checks operate at all our sites in a similar format.
was hoping there would be a computer program that would automatically update
the Manuals to provide the Planner.
was your view that the use of the computer would make this more secure and
view has not changed since five years ago.
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.
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.
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 wasn’t programmed into it in
the first place.
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.
services are not prioritized they all have to be done very month.
happens if you go off site.
contractors or anyone else can look at the planner and see what checks they
have to do.
you are still reactive instead of proactive.
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
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.
fact is that particular check in question wasn’t 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
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.
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 doesn’t count as the computer would only be a glorified maintenance
proactive and not particularly safe.
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
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.
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
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?
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
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
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.
then explained the drawing of the Liquid Waste Pre-Heater system.
much are you proposing to burn off each year?
are trying to save greenhouse gases by taking on this approach as less gas is
is being done with the waste at present?
waste is being sent to Transpacific who separate the solid, water and
had raised in the past Co-generation opportunities – pleased to see this, it is
a good move.
is early days we have just received the proposal back from the designers.
a concept it appears good
other benefit that the flammable waste will go thru this preheating as well
increasing it’s flammability. Our waste mixes change. Waste goes thru the
combustor at 3 litres a minute which is not a major injection into the
there any toxic by-products from those being burnt?
caustic products will be put through the system, so the production of dioxins
and furons will be avoided.
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
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
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.
is the normal combustor start up time.
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.
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