Monday 29 May 2000
Dr Peter Brotherton
Jim Clements (EPA)
Frank Fleer (AWN Consultants)
Mark Cahill – GHD
Gordon Harrison – City of Melbourne
Colleen Hartland (HazMAG)—present for part of the meeting
Thuy Tran (EPA)
Dianne Squires (Footscray Mail)—present at beginning of meeting
ITEM 1. Welcome by the Chair
The chairperson welcomed Colleen Hartland from HazMAG, the committee and others in attendance.
ITEM 2. Apologies
Apologies were received from Marg Leser.
ITEM 3. Confirmation of the Agenda
The Draft Agenda was adopted.
ITEM 4. Confirmation of the Minutes of the meeting 27 April 2000
- Include Cathy Aktypis as an apology.
ITEM 5. Confirmation of the Minutes of the Previous Meeting (11 May 2000)
ACTION As the draft minutes had not been received by all members prior to the meeting, consideration of the draft minutes was deferred until the next meeting.
The Amendements will include the following points:
- pp 9 3rd paragraph Proposed Emissions to Air
Carbon beds would operate at 99.5% efficiency and the combustion at 99.9% efficiency.
- pp 9 4th paragraph
“If need be further discussion about options will proceed” should read “Further advice from EPA on whether options could be addressed will be sought.”
- pp 9 Attachment 7.32
ACTION George to advise at next meeting of the changes needed.
4.1 Advice on Risk Communication (Terminals).
Hugh Jones, Manager DNV Melbourne, will be available at the Committee’s convenience.
George is looking at some advice from Scotland regarding community consultations about benzine emissions
ACTION George will make a presentation to the CICCC before the Public Forum.
ITEM 6. Correspondence In.
See Attachment 4.
An Email letter was received from Greenpeace, and a response from Terminals. These have been circulated, and posted to the CICCC web site.
ITEM 7. Preliminary Views on the Terminal’s proposal (EPA)
Jim said that Scott Maloney would continue to work on the proposed development of the Coode Island site, despite his recent move within the Authority.
See Attachment 1.2 Overview
Scott talked about his recent visit overseas to facilities that operate to World’s Best Practice standards. They were in Beaumont & Houston (USA), Rotterdam and Denmark. He said that the facility in Rotterdam was similar to that at Coode Island because it was close to a hospital and school. The other facilities that he visited were positioned further away from these sorts of community services.
Ian asked Scott about his use of the term ‘thermal oxidiser’ rather than using the term ‘combustor’ which the CICCC had been used it using. Scott said that overseas the terms were interchangeable.
See Attachment 1.3 Mobil-Beaumont,Texas
Scott said a ‘flameless thermal oxidiser’ is a large unit with a smaller flame than the combustors talked of last week. The flameless unit has a flame that heats ceramic balls. Chemicals flow around the hot ceramic balls. These units are highly efficient with low emissions but they do use a lot of gas.
Carlo said these units like a steady stream, which would not be the case at Coode Island where many ‘bumps’ would be experienced in the stream flow.
In the States where floating roof tanks for benzine storage are used, each state has different ‘to atmosphere’ standards. These facilities (which discharge to atmosphere) are meeting the US standards. The US requirements focus more on control technology than actual emission concentrations. In some aspects the US standards are lower than those required in Victoria. The floating roofs are internal within a cone roof and the emissions in the space go to thermal oxidisers for processing, when required by State regulations.
The EPA Victoria requires that Terminals provide the most efficient technology for benzine storage.
Frank Fleer said that floating roofs alone would not meet the ground level emission requirements set by the EPA.
Ian T said that floating roofs could be used with better seals to overcome such problems.
Frank Fleer said that was the case with petrol storage where the benzine content was only 5% but at the Terminals site the tanks will contain 100% benzine.
Scott said he did not know if there are any imminent changes to the USA emission to air legislation. While he was visiting these sites he did not see figures about air pollution readings. He said that benzine emissions from Coode are not a major contributor to Melbourne’s air pollution, but are rather a local air factor. Over time and as technology advances the EPA will require Terminals to upgrade.
See Attachment 1.6 Paktank
Scott said that the photo shows a thermal oxidiser (TO) like the one proposed for Coode Island. He said that in the USA all ship loading waste goes to a TO where previously it all went to air.
The combustor is designed so that it does not go higher than the top of the stack.
Carlo said that the flame will not go over the top because
- Extra air is drawn in automatically to cool down the flame
- If the flame temperature moves outside pre-set limits, the unit would shut down.
- The height of the combustor stack
Ian Thomas said the only way to be sure of this is to have a flame arrester above the flame.
See Attachment 1.7 Paktank-Deer Park, Houston
Peter R said some of the tanks are refrigerated at the bottom to keep the contents of the tank cool. This was necessary where the ambient air temperature was high (Houston).
Scott said this was the case for Propylene Oxide and Toluene diiosocyanate. They were not burnt but processed in carbon that is then disposed of when saturated.
Carlo said that in the USA they are not keen on scrubbing Toluene diiosocyanate – they use carbon.
Acrylate tanks have floating roofs and caustic scrubbers. Ship/barge emissions are treated by diesel fired incinerators.
Peter Reddie said that there would not be any chlorinated waste from Terminals. However any vapours that are generated from chlorinated hydrocarbon tanks will be condensed to make a liquid and go back into their respective storage tanks.
See Attachment 1.8 Baytank – Seabrook, Houston
The main vapour control technology used at this site is vapour return to ship. Scott said this is a very complex operation involving a lot of ship pressure evaluation and adjustment. It was difficult to fully evaluate its efficiency because seals may be faulty and the ships can release to atmosphere once they leave the port.
George said this site was exporting materials and so it was easier for them to manage pressures etc. The reverse occurs at Coode Island because Terminals are mainly importing materials. This system would be more difficult to mange in the Terminals situation. At Houston, elevated flares were used for tank breathing losses.
See Attachment 1.10 Van Ommeron-Botelek, Rotterdam
This is a large facility of 356 tanks with 1,000,000cubic metres of storage. They use 1of 3 carbon beds and the efficiency is not very good (80-95%) Acetylene emissions are controlled by tank specific scrubbers. Rail car filling uses refrigeration.
See Attachment 1.12
Europe also requires ship loading emission controls.
See Attachment 1.13
This site is similarly positioned to Terminals at Coode Island. They have carbon beds and a liquid waste stream. The license requirements for these units are not as strict as in Victoria.
George asked how they protected the inhibitor ie maintain product oxygen level. Scott said he did not know, but that there was an inhibitor in the storage tanks. This method had given little product quality so the material was now sent to scrubbers. The
Acrylates go to scrubbers too.
See Attachment 1.16 Shell- Fredericia, Denmark
This is a very modern unit. There is 55% benzine in the product. Vapour is absorbed in a vacuum regenerated carbon absorption vapour recovery unit. There is one unit for storage and another unit for ships. Emissions from trucks also go to tanks. This facility has a very high standard for benzine.
Scott described the vacuum regenerated carbon absorption vapour recovery units used. He said that chemicals are taken off 2 carbon beds by using a vacuum method, rather than by using steam. The chemicals then go back to the tanks. He said that the disadvantage of this system is that there are ranges of chemicals needing to be processed which can be diffiult to manage. It gives a high efficiency product.
George said that a vacuum system can not be used on all chemicals. Terminals have looked closely at this option. , Benzine yes. Coke oven scored BTX and styrene, no. The Huntsman tanks that Terminals propose to use could not cope with he mix of chemicals that would be generated. He said that a $1.5 million facility would only save $20,000 in benzine per annum.
Peter B said there are a number of pluses.
Ian Thomas remarked that it was refreshing to learn of options not considered previously by TPL in its exhaustive appraisal.
Peter R said it is only suitable for single products and not where there is a mix of products.
Peter B asked if crude benzine could go through a vacuum absorption unit. George said that the carbon would get poisoned and need to be replaced every 12 months instead of every 4-5 years.
In answer to Colleen’s questions, Scott said he had not met with community groups or looked at the safety aspect. He said that was WorkCover’s area. He was concerned about air emissions and other environmental issues.
He said there was a similar group to the CICCC in Houston. They are called Bay Watch (ha ha). There may also be a group in Rotterdam.
Frank F asked if carbon beds were used where the community was living in close proximity. Scott said that he was not sure. The German standards that are used in Demark are designed to achieve 5 mg/m3 at the stack. Various factors are monitored and Scott can access the data associated with some of these. Scott has data from Denmark that shows they have achieved low emissions.
Murray queried whether the German standard for benzine was to be applied in Victoria, and EPA confirmed it was. German standards require that levels be measured at the stack, while the Victorian standard requires measures to be made at ground level.
Scott said the ground level reading was more relevant because it was giving a reading for the combined emissions at ground level of all localised stack emissions and not from just one stack.
Jim said that continuous monitoring in some stacks could be required.
Ian Thomas said that ground level concentrations are modelled, not measured.
The development plan at Terminals will consider the following matters when designing the units required to endeavour to ensure that the ground level readings will be of the highest standard possible:
- Predict the emissions from the stack
- Measure the emissions in the stack
- Predict the worst case weather scenarios
Scott said that operators will be required to do their own monitoring. Presently the EPA occasionally does a random check at Coode Island but in general the EPA’s monitoring visits are pre arranged with Terminals. When inspecting the site, the EPA looks closely at Terminal’s history of monitoring. All the proposed monitoring details for the Terminals site will be available to the CICCC once the application is completed.
Jim said that each option proposed by Terminals was to contain details about the Greenhouse emission implications of the option. There are no recorded figures to indicate the Greenhouse load from the site to date. Jim said that he understands that the legislation for Ozone depleting substances will be up for review shortly.
Jim said that as way of improving our national Greenhouse emissions EPA were presently reviewing air quality management in Victoria, with a view to including consideration of greenhouse gas emissions.
Scott would be pleased to take phone calls from anyone who may require further information about the sites he visited overseas.
See Attachments 2.1 – 2.9 EPA Presentation
Frank Fleer said the Works Approval application is expected to be at least 200 pages in length.
Jim assured the CICCC that he expects the detail in the application to be appropriate and may be used as a model for other companies to follow. If necessary, the EPA will look at further regulatory changes in relation to the Works Approval Application report requirements in the future. There will be a future conference held for the community, EPA and Terminals to discuss the application. An independent chair will be appointed for this meeting.
Ongoing Work Approval Applications will address any needs to upgrade the site over time, so that would best practise is maintain.
Frank L said that the impacts of air emissions are what drive standards. The following are considered
- Effect on human health
- Effect of odours
- Effects of vegetation
Robin S said the Victorian SEPP Air requirements were last reviewed in 1988. He added that the Victorian SEPP Air review was not very comprehensive and agreed with EPA that a further review was warranted.
Jim said it was these standards that the EPA used. He said the EPA required an even higher standard for benzine emissions than that required Federally. He said he could not comment about the national standard requirements and that if the CICCC required more detailed information, they would need to talk to someone that worked in the policy area. He said that there would be an announcement made on Friday about a review of the Victorian SEPP. The EPA technical working group are looking at some of the associated issues regarding matters like monitoring of morbidity/mortality levels. Murray reaffirmed the position of the Department of Human Services that was provided on 24th February (see addendum to Minutes of 13 April 2000).
Jim told the Committee that combustion is one option for treatment of general chemical vapours, and that further information is required for full assessment. EPA’s view is that possible alternative options are available, and EPA has requested Terminals to further consider options for vapour recovery of . Jim reminded the Committee of the Government’s requirement that the facility must meet “the highest possible standards of environmental responsibility”.
Ian Thomas asked whether EPA was locked into combustion/incineration, as rumour had it, and if so, why? Jim replied “No”.
Terminals will be able to put forward a number of options in their Works Approval Application, but the EPA require them to state their preferred option. This requirement is not explicitly legislated but the legislation has been written with the stated intention that companies state the above.
Robin S asked whether EPA would be able to process a Works Approval application if if Terminals submitted 2 or 3 options, and stated that they could ‘live with’ any of these, but preferred one to the others? Jim said he did not think this would be viable proposition. He said that at this stage they did not have enough information about the proposed development of the site to make much comment about preferences. ACTION. CICCC to write to the EPA and urgently seek a formal response regarding the constraints EPA would impose on options submitted by a proponent in a Works Approval application.
Peter B said that the 5 member groups of the CEG (Combined Environment Groups) want a number of options to be proposed , and that Marg Leser had also asked him to present to the meeting her view that options were needed.
ITEM 8. Upgrade of the Plant – resumption of discussion from previous meeting (Peter Reddie, Terminals)
See Attachment 3.1
Most of the stock stored at Terminals is imported. Pure and crude benzine are the products of greatest throughput stored on the site. The next group is non-hazardous, followed by propylene oxide and acrylates. Of the flammable liquids the main ones are Ethanol, Toluene and other solvents. The chemical of the highest hazard stored on the site is Propylene Oxide.
See Attachment 3.2
This shows the volume of material that would become air emissions if no vapour management were done, and which has to be appropriately managed to meet EPA standards. These levels are what would be emitted if the materials were stored in a normal open API 650 tank without any emission controls fitted.
Propylene Oxide is by far the largest product requiring effective management. It is a very volatile product.
Phenol is the most toxic for mortality.
See Attachment 3.3
The long columns show the present situation of air emissions at Terminals where the material is stored in pressure tanks. The air emissions from benzine (7.5 tons to air), acrylate (12 tonnes to air) and chlorinated hydrocarbons (1.8 tonnes) are too high at present. There are no complaints from the public about the benzine emissions because they cannot be smelt, however there are many complaints about the acrylate because it is very smelly. The wastes from chlorinated hydrocarbons are currently treated in activated carbon beds and then incinerated off-site.
See Attachment 3.4
This shows which technology the future proposed upgraded Terminals site will use and the amounts of ‘ emissions to air’ that will be controlled by each piece of technology so that these products no longer go to the air. Peter said that in addition, the presently accumulated 60 tonnes of liquid waste will also be avoided in this proposed new design.
Benzine, ethanol and toluene will go to the combustor and activated carbon beds will be used for toluene diioscyanate
This proposed new design will use about the same amount of energy presently used on site, per annum.
The small combustor will be used to make hot water.
Terminals presently have 4 ignition points on the site via 4 steam boilers. The proposed upgraded site would have only 2 (combustors).
The streams that need treatment would be recycled. They are propylene oxide and chlorinated hydrocarbons.
Others would go as air emissions. They are acrylates, benzines and other flammable liquids.
See Attachment 3.5
This slide shows the present emissions to air at Terminals and the proposed future emissions to air.
Robin S asked that a similar graph be used for the other options proposed by Terminals in their Works Approval Application.
Carlo said that the first column (combustion) shows that Terminals are not meeting the present EPA requirements for air emissions. He said this occurs only at peak times when they are unloading ships. He said that presently the EPA allows about 30 tonnes per year to go to air.
See Attachment 4
Peter R referred to the e-mail received by Greenpeace. He said that Terminals will not be releasing any dioxins or furans to air, from the new combustors that are proposed.
Ian T said that the CICCC should consider the upgrades that have been made by Terminals at their Port Botany site.
Peter R said that people who worked on the Port Botany site are now working on this upgrade at Coode Island. They are George Horman and Wayne Jarman.
He added that the Port Botany site was now 20 years old and the Coode Island site is 40 years old. Port Botany had expansion in ’86, ’89, and ’96.
Ian Thomas said port Botany does not have incineration, but successfully uses two twin activated carbon beds.
The timetable now is
Mid June – Finalise the EPA Works Approval
– Terminals discussions with EPA about the process
In the following 2 weeks -Acceptance Notification from EPA
-Allow for the 35-45 days for Department of Infrastructure responses
– CICCC have 45 days to prepare a response before the conference
– -community has 21 days to make submissions
Section 20b Conference – Facilitate the community conference 2 weeks after closing date for public submissions
ACTION Jim said that he would need to ask advice regarding whether or not the responses to the proposal from the various departments will be made available to the CICCC.
Jim was asked about the process for appointing an independent chair for the community conference. Peter B said that the only conference he had ever attended had been held in a very formal manner that may be intimidating to many members of the community if it were used as a model.
Ted asked where the proposed combustors were manufactured. He said the graphs that were presented meant little to him. He said the community will be asking him what goes into the combustor, what comes out and what will it do when it comes out?
George said the combustors could be purchased from any of the following companies
- John Zinc (USA)
- GCD (Melbourne, Victoria)
- Jordon (USA)
- A possible U.K. source- need further information.
Peter R said that Terminals are only going to use proven technology. He is sceptical about the ‘white cane’ technology of carbon beds.
ACTION. Peter Reddie will prepare a diagram of the 60 tonnes of material (ethanol, benzine, tolyene, etc) that is being proposed to be fed into the combustor, and show exactly the materials (chemical by chemical) and amounts of materials that will go to the air.
See Attachment 5 ‘Typical Exhaust Emissions’
The main materials coming out of the stack will be water and carbon dioxide.
Faye asked about possible malfunctions of the combustors. Frank Fleer said that it could happen if the variables altered. The main ones are
If the temperature goes too high it simply increases the efficiency of the destruction of materials burning in the stack. If the temperature is too low, more unwanted volatiles will be released to the air and the plant will automatically shut down if this starts to occur.
- Gas supply
The amount of the gas flow will determine the burning temperature of the flame. If there is a change, an alarm will sound and the plant will shut down.
Peter R said that the safety design features of the combustor included
- Flame arresters
- Anti flash back jets
- Flame cut monitors
- Seal ports
- Automatic switch down valves
- Liquid cannot pass into the gas jet burners
- Separation distance from the storage tanks of 25 metres
- High temperature thermo couple
Robin S made a quick comparison between the 60,000 litres of liquid waste that is being proposed to be burnt through the combustors and the 30 litres of fuel that is generated by the operation of a single car in one week. The 60,000 litres is equivalent to the amount released to the atmosphere of 40 cars per year, or one part in 30,000 of the amount from Melbourne’s total car fleet of (say) 1.2 million cars.
Peter R said that compared to other consumers of energy within Victoria, Terminals at Coode Island were not large consumers of energy and so were not contributing greatly to the greenhouse effect.
Ian T reiterated his concerns about having an unprotected flame at the bottom of the stack.
George said he has asked the manufactures for information about arresters that may be available but he has not heard from them yet. He said that the concern about possible accident fires was something that related to the whole of the site and not just the areas where the combustors may be sited.
Ian Thomas expressed concern that the ‘lesson’ given to TPL at the last meeting appears to be ignored as TPL is going ahead with incineration.
Peter R said that Terminals staff met straight after the CICCC meeting of 11 May, 2000. He said they had tried to address the concerns of the CICCC as mentioned at the last meeting. They were
- Concerns about the idea that ‘one size fits all’
- Combustion technology
- What other wastes on other sites in Victoria are being put through combustors
- Are there other options to consider
Robin S suggested that the future letter from the EPA may assist Terminals with the formulation of some sub options .
In response to a concern that combustors might be used to burn liquid waste from other sites in Melbourne, Peter Reddie explained that the combustor flues could not be adapted in future, to burn liquid wastes. Any proposed changes would always need to be approved and closely scrutinised by the EPA.
Gordon said he was concerned that the CICCC maybe finding it difficult to listen to all the information given at this meeting, given the length of the meeting. He suggested that the information presented may need to be represented in future.
ITEM 12. The Manchester Agreement.
Ian T said that copies of this report were first tabled in October 1999. Such an agreement would define agreements made between the community and Terminals in relation to the operations, design expectations and constructions at Coode Island.
ACTION. Robin S, Ian T and a Terminals representative will develop a draft for the CICCC to consider at the next meeting.
Jim asked if the Manchester Agreement was any different to the EPA Works Approval Report requirements?
Ian T said it was different in that it was an agreement/commitment between the community and the company.
Greg raised the point that the Manchester Agreement appeared to be a similar concept to the EPA’s Environment Improvement Plan process. Frank F said he agreed with Greg’s statement.
Deborah said she thought such an agreement would be of more significance to the community than the EPA Works Approval agreement.
Michael said that the present management at Terminals was well appreciated for its willingness to be open and transparent. He said the CICCC had to plan for the possibility in future that such an amenable management style may not be in place.
ITEM 14 Planning for the Community Forum
- Change the date of the Public forum to 29 June 2000.
- It will be held at the City of Maribyrnong municipal buildings.
- 6.30pm nibbles
- Chair – Robin Saunders
- If two or three CICCC would like to make a presentation please contact Robin.
- The following activities need to be organised
Prepare a flier
Prepare an agenda
Advertise (Peter R, Deb & Melbourne City Council to assist)
- Ground rules for the Terminals presentation need to be developed.
ITEM 18 Other Business
See Attachment 6
Letter to the CICCC from the Health, Safety and Environment Sub-Committee
Close 11.45 pm
Meeting. Thursday 15 June, 2000
**Note New Date Forum 29 June
Meeting 13 July, 2000
CICCC ATTACHMENTS TO DRAFT MINUTES 27 April 2000
Attachment 1 Overheads EPA Presentation- Scott Maloney
Attachment 2 Overheads EPA Presentation- Jim Clements
Attachment 3.1 – 3.7 Overheads Terminals Presentation – Upgrade of the Plant
Attachment 4 Correspondence between Greenpeace and Terminals
Attachment 5 Typical Exhaust Emissions
Attachment 6 Letter to the CICCC from the HSESC
Attachment 7 CICCC Correspondence to Steve Bracks
Attachment 8 Draft Confidentiality Procedures – Peter Brotherton
Attachment 9 CICCC Media Release 11 May 2000
** These attachments will be sent by post to those who have received e-mailed minutes.