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8/7/2019 APS_compiled

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Annual Performance StatementCalender Year 2010

XYZ GAS REFININGHolder 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

ConditionArea

Condition

Reference

Condition Description Condition

Complied

with?Amenity A1 Offensive odours must not be discharged

beyond the boundaries of the premises.Yes

Amenity A2 Unacceptable noise (including vibration)

must not be emitted beyond the boundaries

of the premises

Yes

Dischargesto air

DA1 Discharge of waste to air must be inaccordance with the 'Discharge to Air' Table

No

Discharges

to air

DA2 Visible emissions to air other than steam

must not be discharged from the premises.No

Discharges

to water

DW1 Stormwater discharged from the premises

must not be contaminated with waste.No

Discharges

to water

DW2 Discharge of waste to surface waters must

be in accordance with the 'Discharge to

Water' Table.

No

Discharge to

land

DL1 You must not contaminate land or

groundwater.No

Generalconditions

G1 Waste from the premises must not bedischarged to the environment except inaccordancewith this licence.

No


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Generalconditions

G2 You must immediately notify EPA of non-compliance with any condition of thislicence.

No

Generalconditions

G3 By 30 September each year you mustsubmit an annual performance statementto EPA for the

previous financial year in accordance withthe Annual performance statementguidelines (EPAPublication 1320).

Yes

Generalconditions

G4 Documents and monitoring records used forpreparation of the annual performancestatementmust be retained at the premises for sevenyears from the date of each statement.

Yes

General

conditions

G5 You must implement a monitoring program

that enables you and EPA to determinecompliance with this licence

Yes

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.

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.


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ATTACHMENT A

Details of Non-Compliance with LicenceCondition

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.


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ATTACHMENT A

Details of Non-Compliance with Licence

Condition

DA2.Visible emissions to air other than steam must not be

discharged from the premises.

_____________________________________________________________________________________


3-March-2009

_____________________________________________________________________________________


Visible emissions of NOx were discharged from the factory.

_____________________________________________________________________________________


Air pollution in the form of acid rain and visibility impairment

_____________________________________________________________________________________


Failure of the thermal oxidisers burner to readjust fuel and air requirement for clean

burn resulting in the emissions of NOx gas to the environment

_____________________________________________________________________________________


compliance

The plant was shut down and the thermal oxidisers burner was tuned in order to

prevent such off-specification to happen again.

_____________________________________________________________________________________


An alarm system was installed so that the operators will be notified immediately

when an off-specification happens again.


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ATTACHMENT A


Condition

DW1. Stormwater discharged from the premises must not be

contaminated with waste.

_____________________________________________________________________________________


4-August-2009

_____________________________________________________________________________________


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

_____________________________________________________________________________________


High BOD level in stormwater and possible eutrophication in areas of still waters.

_____________________________________________________________________________________


Bund plug of the vessel storing the synthetic lubricant was not in place and

improper containment of spillage

_____________________________________________________________________________________


compliance

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

_____________________________________________________________________________________


A chemical skid is being installed around the storage vessel to prevent future

spillages from flowing into the run-off water system


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ATTACHMENT A


Condition

DW2. Discharge of waste to surface waters must be in accordance

with the 'Discharge to Water' Table.

_____________________________________________________________________________________


4-August-2009

_____________________________________________________________________________________


Water temperature increased to 36C which exceeded 35C, 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.

_____________________________________________________________________________________


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.

_____________________________________________________________________________________


Spillage of synthetic lubricants, hot washing water was used to clean the spillage

which then caused the increase in water temperature to 36C when the water was

to discharge to the run-off water stream

_____________________________________________________________________________________


compliance

The site washed the spillage with hot water. Shoreline was suggested to be used in

cleaning the spillage.

_____________________________________________________________________________________


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 preventcareless incident to take place.


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ATTACHMENT A


Condition

DL1. You must not contaminate land or groundwater.

_____________________________________________________________________________________


4-August-2009

_____________________________________________________________________________________


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

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

____________________________________________________________________________________


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._____________________________________________________________________________________


Dislocations of the lubricant vessel bund plug which resulted in the spillage, which

was not properly contained and removed.

_____________________________________________________________________________________


compliance

Material was flushed to the run-off water system with hot water._____________________________________________________________________________________


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.


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ATTACHMENT A


Condition

G1. Waste from premises must not be discharged to the

environment except in accordance with this license.

_____________________________________________________________________________________


5-May-2009

_____________________________________________________________________________________


Discharge of unlicensed building material to the environment

_____________________________________________________________________________________


Potential harm to human health and unwanted odours

_____________________________________________________________________________________


A building material was being blown offsite from a part of the site undergoing

maintenance work.

_____________________________________________________________________________________


compliance

Nil

_____________________________________________________________________________________


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.


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ATTACHMENT A


Condition

G2. You must immediately notify EPA of non-compliance with any

condition of this license.

_____________________________________________________________________________________


4-August-2009 & 5-August-2009

_____________________________________________________________________________________


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.

_____________________________________________________________________________________


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.

_____________________________________________________________________________________


The site Environment Manager was not notified until after the spill had been flushed

to the run-off water system.

_____________________________________________________________________________________


compliance

Nil

_____________________________________________________________________________________


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.


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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

ntThermal Oxidiser Vent

(DP1)NO2 discharge rate g/min Maximum 20

Thermal Oxidiser Vent

(DP1)SO2 discharge rate g/min Maximum 150


(DP1) H2S discharge rate g/min Maximum 0.05Thermal Oxidiser Vent

(DP1)

Toluene discharge

rateg/min Maximum 0.0002


(DP1)

Benzene discharge

rateg/min Maximum 0.0002

b) Number of samples taken and periods of sampling

Parameters such as NO2, SO2 and H2Sare monitored in a daily basis producing a

total of 365 samples, whereas Toluene and benzene are monitored in monthlybasis 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

taken

Periods of

samplingNO2 g/min 365 DailySO2 g/min 365 DailyH2S g/min 12 Monthly

Toluene g/min 12 MonthlyBenzene 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.

PeriodNO2

(g/min)

SO2

(g/min)

H2S

(g/min)

Toluene

(g/min)

Benzene

(g/min)


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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

31/12/200914.815 120.196 0.012 0.000075 0.000075


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WATER

a) Summary of statistics for discharge limits

Table B-2.1 Licensed discharge limits for water discharges.

Discharge Point Indicator Units Limit TypeAmou

ntWater Discharge Point -

Refinerville Bay

Total organic carbon

discharge limitmg/L Maximum 10

Water Discharge Point -

Refinerville Bay

Total residual

chlorine discharge

limit

mg/L Maximum 0.1


Refinerville Bay

Oil and grease

discharge limitmg/L Maximum 5


Refinerville Bay

Suspended solids

discharge limitmg/L

Annual

Median5

Water Discharge Point -Refinerville Bay

BTEX discharge limit mg/L Maximum 0.7


Refinerville Bay

Copper discharge

limitmg/L Maximum 0.1


Refinerville BayZinc discharge limit mg/L Maximum 0.5


Refinerville Bay

Nickel discharge

limitmg/L Maximum 0.2


Refinerville Bay

Dissolved oxygen

discharge limitmg/L Minimum 5


Refinerville Bay Temperature C Maximum 35

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 eachindicator.

Indicator UnitsNo. of samples

takenPeriods ofsampling

Total OrganicCarbon

mg/L 365 Daily

Total ResidueChlorine

mg/L 52 Weekly

Oil and Grease mg/L 52 WeeklySuspended solids mg/L 12 Monthly

BTEX mg/L 12 MonthlyCopper mg/L 12 Monthly

Zinc mg/L 12 MonthlyNickel mg/L 12 Monthly

Dissolved Oxygen mg/L 12 Monthly


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Temperature C 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.

Period

Total

Organic

Carbon

(mg/L)

Total

Residue

Chlorine

(mg/L)

Oil and

Grease

(mg/L)

Temperat

ure

(C)

Suspen

ded

Solids

(mg/L)

1/1/2009 to 31/3/2009 2.467


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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 BODlevel 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 anaerobictreatment.

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 theimplementation 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.


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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 bymoisture. 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 gassorbent material into thegas stream and a particulate matter control device to remove reaction products, excesssorbent 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 spraydryer absorbers (SDAs). Spray dryer absorbers are also called semi-dry scrubbers orspray dryers. Dry scrubbing systems are often used to remove odorous and corrosivegases from wastewater treatment plant operations. The media used is typically anactivated alumina compound impregnated with materials to handle specific gases suchas hydrogen sulfide.

Dry sorbent injection:

Addition of an alkaline material (hydrated lime or soda ash) into the gas stream to reactwith the acid gases. Sorbent can be inject directly into different location such as thecombustion process, flu gas duct or open reaction chamber if exist. The acid gases reactwith the alkaline sorbents to form solid salts which are removed in the particulatecontrol device. These simple systems can achieve only limited acid gas (SO2 and HCl)removal efficiencies. Higher collection efficiencies can be achieved by increasing theflue gas. These devices have been used on medical waste incinerators and a fewmunicipal waste combustors.

In spray dryer absorbers:

The flue gases are introduced into an absorbing tower (dryer) where the gases arecontacted with a finely atomized alkaline slurry. Acid gases are absorbed by the slurrymixture and react to form solid salts which are removed by the particulate controldevice. The heat of the flue gas is used to evaporate all the water droplets, leaving anon-saturated flue gas to exit the absorber tower. Spray dryers are capable of achievinghigh (>80%) acid gas removal efficiencies. These devices have been used on industrialand utility boilers and municipal wasteincinerators.
http://en.wikipedia.org/wiki/Acid_gashttp://en.wikipedia.org/wiki/Sorbenthttp://en.wikipedia.org/wiki/Flue_gashttp://en.wikipedia.org/w/index.php?title=Dry_sorbent_injection&action=edit&redlink=1http://en.wikipedia.org/wiki/Spray_dryerhttp://en.wikipedia.org/wiki/Spray_dryerhttp://en.wikipedia.org/wiki/Industrial_wastewater_treatmenthttp://en.wikipedia.org/wiki/Activated_aluminahttp://en.wikipedia.org/wiki/Hydrogen_sulfidehttp://en.wikipedia.org/wiki/Sorbenthttp://en.wikipedia.org/wiki/Salthttp://en.wikipedia.org/wiki/Medical_wastehttp://en.wikipedia.org/wiki/Municipal_wastehttp://en.wikipedia.org/wiki/Flue_gashttp://en.wikipedia.org/wiki/Slurryhttp://en.wikipedia.org/wiki/Salthttp://en.wikipedia.org/wiki/Absorption_(chemistry)http://en.wikipedia.org/wiki/Boilerhttp://en.wikipedia.org/wiki/Municipal_wastehttp://en.wikipedia.org/wiki/Incineratorhttp://en.wikipedia.org/wiki/Acid_gashttp://en.wikipedia.org/wiki/Sorbenthttp://en.wikipedia.org/wiki/Flue_gashttp://en.wikipedia.org/w/index.php?title=Dry_sorbent_injection&action=edit&redlink=1http://en.wikipedia.org/wiki/Spray_dryerhttp://en.wikipedia.org/wiki/Spray_dryerhttp://en.wikipedia.org/wiki/Industrial_wastewater_treatmenthttp://en.wikipedia.org/wiki/Activated_aluminahttp://en.wikipedia.org/wiki/Hydrogen_sulfidehttp://en.wikipedia.org/wiki/Sorbenthttp://en.wikipedia.org/wiki/Salthttp://en.wikipedia.org/wiki/Medical_wastehttp://en.wikipedia.org/wiki/Municipal_wastehttp://en.wikipedia.org/wiki/Flue_gashttp://en.wikipedia.org/wiki/Slurryhttp://en.wikipedia.org/wiki/Salthttp://en.wikipedia.org/wiki/Absorption_(chemistry)http://en.wikipedia.org/wiki/Boilerhttp://en.wikipedia.org/wiki/Municipal_wastehttp://en.wikipedia.org/wiki/Incinerator

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