Final compliance audit report: Bluescope Steel Pty Ltd · FINAL COMPLIANCE AUDIT REPORT BLUESCOPE...

FINAL

COMPLIANCE AUDIT REPORT

BLUESCOPE STEEL (AIS) PTY LTD FIVE ISLANDS ROAD

PORT KEMBLA NSW 2505

FEBRUARY 2012

This report has been prepared to present the findings of the audit carried out and no responsibility is accepted for its use in any other context, or for any other purpose.

© 2012 State of NSW and Environment Protection Authority

The State of NSW and the Environment Protection Authority (EPA) are pleased to allow this material to be reproduced in whole or in part for educational and non-commercial use, provided the meaning is unchanged and its source, publisher and authorship are acknowledged.

The EPA has compiled this publication in good faith, exercising all due care and attention. No representation is made about the accuracy, completeness or suitability of the information in this publication for any particular purpose. The EPA shall not be liable for any damage which may occur to any person or organisation taking action or not on the basis of this publication. Readers should seek appropriate advice when applying the information to their specific needs.

Published by: Environment Protection Authority 59–61 Goulburn Street, Sydney PO Box A290, Sydney South 1232 Phone: (02) 9995 5000 (switchboard) Phone: 131 555 (environment information and publications requests) Fax: (02) 9995 5999 TTY users: phone 133 677, then ask for 131 555 Speak and listen users: phone 1300 555 727, then ask for 131 555 Email: [email protected] Website: www.epa.nsw.gov.au

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ISBN 978 1 74293 607 9 EPA 2012/0330 April 2012

EXECUTIVE SUMMARY

An Environment Protection Authority (EPA), Compliance Audit was undertaken at the BlueScope Steel (AIS) Pty Ltd Port Kembla Steelworks. The site was audited as part of a state-wide program of audits focusing on the management of major environmental risks associated with the activities undertaken at the site. The audit also focussed on emergency management procedures to be used by the licensee in the event of an incident occurring that is or is likely to impact on the environment or on the local community. The main objectives of the audit were to assess compliance with the requirements of Environment Protection Licence 6092 relating to the management of major environmental risks and emergency management planning, and to recommend an action program to be implemented by the licensee to address any non-compliance identified during the audit.

Assessment of compliance was undertaken using information collected during a detailed audit inspection, information supplied by the enterprise, and a review of records and documentation relating to the premises. The procedures and protocols for conducting compliance audits are detailed in the EPA Compliance Audit Handbook. The audit inspections were carried out by officers of the EPA on 12 and 13 December 2011.

The findings of the audit indicate that the enterprise was not complying with some of the conditions attached to Environment Protection Licence 6092 issued under the Protection of the Environment Operations Act 1997.

The non-compliance related to:

Loss of containment of COG main residues and the potential for contamination of land and groundwater

The following issues of concern were identified through further observations:

Loss of containment of tar in the Gas Holder area with the potential to migrate to the Main Drain and into the harbour

Liquid (Water) discharge from areas around the BOS Furnaces (including Waste water Treatment Plant and Slag Yard) with the potential to go to Allan’s Creek

Procedures, processes and equipment for managing major environmental pollution incidents

A risk assessment of non-compliances is used to colour code non-compliances according to their environmental significance and an action program has been developed. The action program includes a timeframe for non-compliances to be addressed to ensure the licensee deals with issues raised through the audit process in a timely manner (Table 4.1).

While the risk assessment of non-compliances is used to prioritise actions to be taken, the EPA considers all non-compliances to be important and licensees must ensure that all non-compliances are addressed by the due date specified in the Action Program.

TABLE OF CONTENTS

1.0 ............................................................................................................ 1 INTRODUCTION

1.1 .......................................................................................................... 1 Audit Objective

1.2 ...................................................................................................... 1 Scope of the Audit

1.3 ......................................................................... 1 Audit criteria, evidence and findings

1.4 .............................................................................. 2 Premises and Process Description

1.5 ........................................................... 2 Statutory Instruments Issued to the Enterprise

1.6 ....................................................................... 3 Risk Assessment of Non-compliances

2.0 .............................................................................. 4 ASSESSMENT OF COMPLIANCE

2.1 ................................................................................. 4 Compliance with Audit Criteria

Table 2.1 Assessment of Compliance with Environment Protection Licence No. 6092 ....... 5

3.0 ...................................................................................... 30 FURTHER OBSERVATIONS

4.0 .................................................................................................... 32 ACTION PROGRAM

Table 4.1 Action Program – Environment Protection Licence No. 6092 .......................... 32

APPENDICES

Appendix A Licensee Response to Draft Report

Appendix B Letter covering licensee’s response to Draft Compliance Audit Report

Compliance Audit Report BlueScope Steel (AIS) Pty Ltd

FINAL/FIL11/9621/ DP 1 Environment Protection Authority

1.0 INTRODUCTION

An Environment Protection Authority (EPA), Compliance Audit has been undertaken at the BlueScope Steel (AIS) Pty Ltd Steelworks at Port Kembla. The site was audited as part of a state-wide program of audits focusing on the management of major environmental risks associated with the activities undertaken at the site. The audit also focussed on emergency management procedures employed by licensee in the event of an incident occurring at the site that is or is likely to impact on the environment or on the local community. The audit inspections were undertaken on 12 and 13 December 2011.

The procedures and processes for conducting EPA Compliance Audits are detailed in the Compliance Audit Handbook, which can be accessed on the EPA website at http://www.environment.nsw.gov.au/resources/licensing/cahandbook0613.pdf.

1.1 Audit Objective

The objectives of the audit were

- to determine whether the enterprise is complying with environment protection licence requirements in relation to the audit scope and criteria; and

- to outline a time frame for follow-up action to address any non-compliances identified during the audit.

1.2 Scope of the Audit

The scope of the audit is limited to the examination of the activities undertaken at BlueScope Steel (AIS) Pty Ltd, in relation to the management of major environmental risks.

The temporal scope adopted for assessment of compliance is:

- The day of the audit inspection for assessing compliance with Operating Conditions, relating to the management of major environmental risks and emergency management planning; and

- 12 months prior to the end of the audit inspection for assessing compliance with any Monitoring, Recording and Special Conditions and Pollution Studies and Reduction Programs relating to the audit scope.

1.3 Audit criteria, evidence and findings

Audit criteria (the requirements against which the auditor compares collected audit evidence) are the Conditions attached to Environment Protection Licence Number 6092 issued under the POEO Act to BlueScope Steel (AIS) Pty Ltd, in relation to the management of major environmental risks.

Audit criteria may include any document referred to by the licence, or relevant to a particular condition of the licence.

Audit evidence was collected during discussions with site personnel, examination of documentation provided by the licensee and/or contained on EPA files, together with observations made during the audit inspection.

http://www.environment.nsw.gov.au/resources/licensing/cahandbook0613.pdf



Findings of non-compliance with licence conditions are summarised in table 2.1. An Action Program provides a time frame for follow-up action necessary to comply with the licence condition concerned.

1.4 Premises and Process Description

BlueScope Steel (AIS) Pty Ltd operates an integrated steelworks situated on a 760 hectare site approximately 80 kilometres south of Sydney on the NSW south coast at Port Kembla. The facility is located within the Wollongong local government area and is surrounded by industrial and residential premises.

The Port Kembla Steelworks is currently a 2.6 million tonne per year integrated steelworks. Some of the facilities at the site include: Shipping and rail operations, sinter plant, oxygen generation plant, lime kiln, coke ovens, blast furnaces, basic oxygen steelmaking furnaces, continuous slab casters, hot strip mill and plate mill.

BlueScope Steel has an extensive Emergency Management System. Small incidents are managed within one of the 65 departmental emergency plans. When an incident is beyond the resources of a single department or has wider implications across the site, the emergency response can be escalated.

1.5 Statutory Instruments Issued to the Enterprise

The EPA has issued the following statutory instruments to the enterprise:

Licence number 6092 issued under the Protection of the Environment Operations Act 1997.

The scheduled activities undertaken at the premises are Coke production, Iron or steel production (iron ore), Cement or lime handling, Agricultural fertiliser (inorganic), Generation of electrical power from gas, Coal works, Scrap metal processing, Waste storage (other types of waste), Recovery of general waste, Recovery of waste tyres, Mineral processing, Waste storage (waste tyres), Cement or lime production, General chemicals storage , Crushing, grinding or separating, Railway systems activities , Shipping in bulk and Dangerous goods production. The fee scale category of Iron or steel production (iron ore) is > 0 tonne produced.

The anniversary date for the licence is 1 July.

A copy of Licence 6092 can be accessed through the EPA online public register at: http://www.environment.nsw.gov.au/prpoeoapp/searchregister.aspx

http://www.environment.nsw.gov.au/prpoeoapp/searchregister.aspx



1.6 Risk Assessment of Non-compliances

The significance of any non-compliances identified during the audit process are categorised. Following risk assessment of non-compliances, an escalating response relative to the seriousness of the non-compliance is determined to ensure the non-compliance is addressed by the enterprise.

The risk assessment of non-compliances involves assessment of the non-compliance against two criteria; the likelihood of environmental harm occurring and the level of environmental impact as a result of the non-compliance. After these assessments have been made, information is transferred into the risk analysis matrix below.

Likelihood of Environmental Harm Occurring

Certain Likely Less Likely

High Code Red Code Red Code Orange

Moderate Code Red Code Orange Code Yellow

Lev

el o

f E

nvi

ron

men

tal I

mp

act

Low

Code Orange Code Yellow Code Yellow

The assessment of the likelihood of environmental harm occurring and the level of environmental impact allows for the risk assessment of the non-compliance via a colour coding system. A red risk assessment for non-compliance denotes that the non-compliance is of considerable environmental significance and therefore must be dealt with as a matter of priority. An orange risk assessment for non-compliance is still a significant risk of harm to the environment however can be given a lower priority than a red risk assessment. A yellow risk assessment for non-compliance indicates that the non-compliance could receive a lower priority but must be addressed.

There are also a number of licence conditions that do not have a direct environmental significance, but are still important to the integrity of the regulatory system. These conditions relate to administrative, monitoring and reporting requirements. Non-compliance of these conditions is given a blue colour code.

The colour code is used as the basis for deciding on the priority of remedial action required by the licensee and the timeframe within which the non-compliance needs to be addressed. This information is presented in the action program alongside the target/action date for the non-compliance to be addressed.

While the risk assessment of non-compliances is used to prioritise actions to be taken, the EPA considers all non-compliances are important and licensees must ensure that all non-compliances are addressed as soon as possible.



2.0 ASSESSMENT OF COMPLIANCE

2.1 Compliance with Audit Criteria

Compliance was assessed against the licensing requirements of the POEO Act, and the requirements of Environment Protection Licence Number 6092 relating to the audit scope and criteria.

Assessment of compliance was undertaken by a detailed site inspection and review of all records and documentation relating to the audit scope and criteria as required by the licence issued to the licensee.

The findings of the audit indicate that the conditions of the environment protection licence, relating to the audit scope were being complied with.

Details of assessment are presented in Table 2.1.


Table 2.1 Assessment of Compliance with Environment Protection Licence No. 6092

Statutory Instrument: Environment Protection Licence No. 6092

Condition No. Compliance/ Risk assessment for

non-compliance *

Comment Action required by licensee

O Operating Conditions

The audit assessment is based upon evidence relating to the period limited to on the day of the audit inspection. Managing major environmental risks associated with water / land pollution O1.1 Licensed

activities must be carried out in a competent manner

Yes

Identification of Major Environmental Risks

The licensee has identified major environmental risks associated with the pollution of stormwater at the premises. This includes pollution of stormwater from the following sources:

Potential for release of firewater to stormwater during fire fighting activities.

Potential for pollution by Coke Ovens Gas (COG) condensate overflowing into the drain system and into Port Kembla Harbour

Loss of containment of COG main residues and subsequent environmental contamination

Potential for loss of containment of tar in the Gas Holder area, and possible migration to Main Drain and into the harbour

Potential for an oil spill to occur in Energy Services Department resulting in discharge of oil into works drains and the harbour

Potential for stormwater to become polluted from discharges of liquid (Water) from areas around the Basic Oxygen Steelmaking (BOS) Furnaces (including Waste water Treatment Plant and Slag Yard).

The auditors did not identify any other major environmental risks during the site inspection that had not already been identified by the licensee.

See explanation of risk assessment of non-compliances codes on p3.







non-compliance *


Use of controls to minimise the Major Environmental Risks Identified - Release of firewater to stormwater

The licensee has controls in place to manage the major environmental risks identified such as:

The coke ovens recovery basin has capacity to trap contaminated fire water from a fire in the coke ovens/gas processing area

Chemical storage tanks are equipped with secondary spill containment

North Gate Drain Gross Pollutant Trap helps remove floating and settleable contaminants

Some drainage lines lead to engineered depressions where run-off waters can seep away. This enables some filtration of contaminants prior to discharge to the receiving waters

Training of staff in the use and managements of controls and their roles in emergency response (Drains are marked to indicate if they connect to the harbour; inlets can be sandbagged to filter fire water)

Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks

The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes:

Monitoring the water level in the coke ovens recovery basin

Undertaking routine inspections/maintenance/calibration of monitoring and control equipment






non-compliance *


Use of controls to minimise the Major Environmental Risks Identified - Pollution caused by COG condensate overflowing into the drain system and into Port Kembla Harbour


Seal pot discharge points have installed concrete collection wells

A regular seal pot collection well pump out regime is in place for all COG seal pots (the pump out is returned to the coke works biological treatment plant)

The coke ovens recovery basin provides backup containment for leaks and spills from the coke ovens and gas processing areas

Waters from the biological treatment plant and coke ovens recovery basin can be re-used in the hot coke quenching process


The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:

Biological treatment plant effluent is tested daily to monitor the level of treatment performance

Testing and calibration of equipment (incl. instrumented equipment)

Monitoring water quality at the premises licensed discharge points (minimum 8 day cycle)






non-compliance *


No

Code Red

Use of controls to minimise the Major Environmental Risks Identified - Loss of containment of COG main residues and subsequent environmental contamination


A variety of steel and fibreglass tanks/containers are used for the storage of COG main residues. However accelerated corrosion from steel storage tanks partially buried in slag material is likely to increase the risk of liquids leaking from the containers. The valve housing of another steel storage tank was in contact with the slag base material potentially increasing the risk of corrosion damage to the valve at the lowest point of the storage tank. An indication of spillages onto the slag base was observed in one area (Please refer to the photograph following Table 2.1).

Liquids in the residues are permitted to evaporate so that the material is maintained in a solid form for secure handling and reduced risk of spillage

All open-top tanks are fitted with rain covers in an attempt to prevent the ingress of rainwater. However it was identified that some of the rain covers fitted to open top tanks may not have extended adequately beyond the sides of the tank to exclude wind blown rain from entering the tank

In two of the four areas where COG main residues are stored secondary spill containment was provided so that any leaks and/or spills could be recovered without causing pollution

The EPA is concerned that any loss of containment from the tanks in three of the four storage areas has the potential to pollute surface, groundwater and soil.

The licensee must implement controls and

monitor the effectiveness of those controls to

minimise the likelihood of discharge of stored COG main residues from the

site.






non-compliance *



The licensee monitors the effectiveness of some of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:

Inspection on tanks and containment structures to detect leaks and spills

Monitoring integrity to detect infiltration into the ground at three of the four storage areas is not undertaken.

The frequency of tank integrity testing is not considered adequate to detect loss of containment

Note: Condition U15 of the licence requires the development of a coke ovens gas mains solids management plan which details appropriate storage and disposal methodologies that will be implemented for current and future coke ovens gas mains solids. (See below for Pollution Reduction Programs (PRP))

Yes Use of controls to minimise the Major Environmental Risks Identified - Loss of containment of tar in the Gas Holder area, and possible migration to the Main Drain and into the harbour


Tar make-up tanks have secondary containment installed to collect leaks and spills

A concrete lined collection pit is installed to intercept tar leakage at the gas holders

Absorbent oil booms are installed in the main drain for the interception and






non-compliance *


removal of floating contaminants

Some spillages can be diverted to and contained the coke ovens recovery basin for subsequent removal

Please refer to Further Observations. Monitoring the effectiveness of the controls used by the licensee to manage the

Major Environmental Risks


Frequent inspections and pump-out of tar collection sumps and Main drain oil booms

Water quality monitoring at the licensed discharge points (minimum 4 day cycle)

Note: Condition U20 of the licence requires investigation of every activity with potential to cause PAH (Polycyclic aromatic hydrocarbons) contamination to the soils and groundwater at the Gas Holder Compound. The report of the outcomes of the investigation was due on 31 December 2011 and therefore beyond scope of this audit.

It is noted that this report has been provided.

Use of controls to minimise the Major Environmental Risks Identified - Oil Spill incident occurring in the Energy Services area resulting in discharge of oil into the drain system and into Port Kembla Harbour


Spills directed to the salt water inlet channel skimmers for collection

Emergency boom available as a backup if required






non-compliance *




Oil tanks monitored for loss of containment

Frequent inspections and maintenance of oil skimmer

Integrity checks – tanks

Use of controls to minimise the Major Environmental Risks Identified - Liquid (Water) discharge from areas around the BOS Furnaces (including Waste water Treatment Plant and Slag Yard) with the potential to go to drain


Waste water Treatment Plant Secondary/tertiary containment collects leaks and spills which are then pumped to the process tanks

Sensors detect pipeline pressure drop to indicate a loss of containment. In the event of an alarm the licensee can isolate the pipe and recover the spillage by pumping back to the treatment plant storage vessels

Please refer to Further Observations.



Monitoring, alarms and trips (levels, pressures)






non-compliance *


Testing and calibration of equipment (incl. instrumented equipment)

Integrity checks – tanks

Visual checks – 4 hourly inspections (no leaks occurred in the previous 12 months)

Managing major environmental risks associated with air pollution

Yes Identification of Major Environmental Risks

The licensee has identified the major environmental risks associated with the pollution of air at the premises. This includes pollution of air due to:

Loss of containment (LOC) of coke ovens gas

Coke ovens Waste Heat stack emissions

Emissions resulting from the loss of electrical power to the coke ovens batteries

High voltage loss of electric power to the Steelworks

Hazards associated with loss of functionality of coke ovens exhausters (including resulting in a fire and/or explosion)

Air emissions linked to No. 5 blast furnace operational scenarios

Plant-wide kish emissions to the atmosphere

Fugitive dust emissions at the Desulphurisation Treatment plant

Machine Scarfing - Iron Oxide fumes escaping to atmosphere via the Scarfer stack

Fugitive dust emissions from the Port Kembla Recycling Area and other Alliances and Recycling managed areas

The auditors did not identify any other major environmental risks during the site inspection that had not already been identified by the licensee.






non-compliance *


Use of controls to minimise the Major Environmental Risks Identified - LOC of coke ovens gas


Written procedure ensures charging of the oven follows the correct sequence

Charging operations are interlocked, to assist the driver of the charger car to check for leaks, correctly complete a step in the sequence prior to moving to the next step in the sequence

Steam is introduced into the valve box to establish a draft into the collector main

Regular surveying of the oven tops ensures correct alignment of the charger car with the oven lids thereby assisting with the control of leaks

All mechanisms are included in a maintenance strategy (e.g. valve box and lid seal cleaning)

Competency training together with regular refresher training of operators



CCTV in the charger car assists the operator to confirm standpipe caps are closed and/or not emitting raw COG. CCTV is also used to assist control room operators in detecting any leaks of COG

Alarms inform the driver of the charger car of any problem with the mechanisms






non-compliance *


and/or sequence of charging the ovens

Alarm prioritisation procedure at the Coke ovens control room

Visual checks – confirm the operation of alarms

Alarms are logged for trend analysis which informs maintenance plans

Written Procedures (compliance sign-off; regular management review)

Use of controls to minimise the Major Environmental Risks Identified – Coke ovens Waste Heat stack emissions


Managing carbon growth on oven brickwork to reduce the escape of raw COG into the oven flues

Refractory Repair Team – Ceramic welding

Back scatter meters in the stacks, with alarms in the control room help identify ovens in need of maintenance/repair



Internal inspections of ovens informs the repair frequency required

Monitoring (additional temperature checks where coking time may have been extended)

Fortnightly review of alarm trends to inform repair scheduling for problem ovens






non-compliance *


Quarterly stack emissions testing

Monitoring instruments are on a monthly maintenance and calibration schedule.

Visual inspections (CCTV can monitor stack emissions)

Use of controls to minimise the Major Environmental Risks Identified - Emissions resulting from the loss of electrical power to the coke ovens batteries


Batteries are fitted with emergency flares to reduce the amount of contaminants being emitted under emergency conditions

Emergency flares have multiple backup igniters to help ensure flaring of raw COG

Un-interruptible Power Supply (UPS) backup power for the control room and emergency igniters to start raw COG flaring

Maintenance and checks of equipment



Written Procedures (controlled copies)

UPS – Annual load test and 5 year battery replacement






non-compliance *


Use of controls to minimise the Major Environmental Risks Identified – High Voltage loss of electric power to the Steelworks


5 incoming high voltage supplies and 4 substations designed to provide backup in the event of a loss of an incomer as well as minimising the parts of the plant affected by a power outage

All electrical circuits have protection designed to isolate a fault from the bulk of the distribution network

Backup systems – including un-interruptible power supplies at various departments

Maintenance and inspection regime

Diesel back-up generators installed to provide safe shutdown, run alarms and small pumps, prevent oil fires and LOC

Flares are installed for the purpose of reducing the concentrations of contaminants released to the atmosphere



Written Procedures (controlled copies)






non-compliance *


Monitoring, alarms inform control room

Thermal cameras monitor flare igniters

Maintenance schedule for flare igniters

Testing regime in place for monitoring systems

Use of controls to minimise the Major Environmental Risks Identified - Hazards associated with loss of functionality of coke ovens exhausters (including resulting in a fire and/or explosion)


3 of the 5 exhausters draw gases from the coke ovens to the gas processing plant. 2 back-up exhausters are maintained in standby mode

Backup flushing liquor cooling water pumps are provided

A diesel generator is provided to supply backup power to the cooling water pumps in the event of a loss of power

A second layer of backup is provided by steam driven pumps

Emergency raw gas bleeders on the coke ovens, flare excess gas if the gas processing plant fails in order to help reduce the concentration of contaminants in emissions to the atmosphere

The Gas Processing control room is provided with an un-interruptible power supply

Flammable liquid storage tanks at the gas processing area are fitted with fixed rooves to reduce the risk of fire






non-compliance *


o Sensors and alarms on tanks (high and high-high)

o Sensors and alarms in tank farm bund sumps inform the control room in the event of leaks or spills from tanks

o Pressure relief and pressure venting

To coke battery exhausters or

To waste heat stack for dispersion

Control of ignition sources (open flame, smoking, Permit to Work)

Smoke detectors in all switch rooms

Gas detectors (benzene and carbon monoxide) inform the control room of any loss of containment of vapours

A watcher is present to oversee all hot work

Fire fighting systems – including foam and fixed deluge sprays at the gas processing truck loading bay

Change management procedures are in place for process changes

Spill equipment is available for use in the clean-up of minor spills at that site.



Monitoring, alarms, inform the control room about cooling water availability

Regular maintenance ensures the reliability of cooling water low flow alarms






non-compliance *


Fortnightly testing of the backup power generator

Un-interruptible power supply – Annual load test and 5 year battery replacement

Regular bund sump detector simulation testing

Testing and calibration of equipment (incl. instrumented equipment) (3 monthly)

Integrity checks – storage tanks

Training – basic fire training on a 2 year cycle

Fire scenario training

Use of controls to minimise the Major Environmental Risks Identified - Air emissions linked to No. 5 blast furnace operational scenarios


Written procedure to respond to a furnace cooling trend

4 top bleeders release pressure in the furnace vessel to protect against structural damage of the furnace vessel

Formal handover practice involves upper management on site as well as the involvement of extra personnel during abnormal operations (e.g. start-up/shut-down scenarios)

Recirculated off-gas scrubbing system reduces the risk of contaminated waste water discharges

Flammable gas pressure built up can be flared by the inter works gas distribution system to reduce emissions to the atmosphere






non-compliance *


Emergency header tank fitted to the top of the furnace supplies cooling water to help maintain the integrity of the furnace vessel

Diesel power generator back-up system for critical control room functions

Furnace design and setup to fail to a safe condition



Furnace pressure tests conducted post refractory reline

Bleeder trip tests conducted on a 4 year cycle

Maintenance regime for the diesel backup generator to ensure serviceability

Use of controls to minimise the Major Environmental Risks Identified - Plant-wide kish emissions to the atmosphere


Dust extraction hoods installed at the hot metal dumping pits to collect kish when molten iron is poured from the torpedo ladle into the launder

Written procedure ensures risk of emissions can be reduced and high kish emitting activities can be slowed and/or stopped






non-compliance *


Baghouse/Dust catchers/Cyclones

Written procedure to ensure iron dumping does not occur solely due to industrial action



Written Procedures (e.g. monitoring kish pot temperatures prior to tipping)

Kish complaints monitoring and investigation procedure

Manual emission ranking and reporting system for a range of potential kish emitting activities

Maintenance schedule (e.g. baghouse)

Use of controls to minimise the Major Environmental Risks Identified - Fugitive dust emissions at the Desulphurisation Treatment plant


Building enclosure with hood and ducting over the hot metal rail wagons (torpedo ladles)

Spillage prevention procedures (e.g. check level of iron in the ladle before commencement; limiting the lime injection rate; and the height of the injection






non-compliance *


lance)

Bag house to filter the particles from any fume generated during the process prior to discharge to the atmosphere

Treatment process and the baghouse are interlocked to prevent the process occurring without suction to the bag filters



Monitor pressure across the inlet and outlet of the bag house

Alarms on the bag house fan inform the control room of any problem with suction prior to commencing the process

Use of controls to minimise the Major Environmental Risks Identified - Machine Scarfing - Iron Oxide fumes escaping to atmosphere via the Scarfer stack


Electrostatic precipitator with 6 cells to reduce process emissions prior to discharge to the atmosphere

Written procedure (covering the removal of cells in the electrostatic precipitator dust collector for maintenance)

Water sprays at the scarfing lance to knock down heavy particles into a scale






non-compliance *


collection pit

Scarfing process is interlocked to ensure the precipitator and water sprays operate concurrently



Maintenance schedule on electrostatic precipitator (Daily electrode voltage test)

Control room CCTV/visual checks and emission rating and recording system for emissions trend review

Use of controls to minimise the Major Environmental Risks Identified - Fugitive dust emissions from the Port Kembla Recycling Area and other Alliances and Recycling managed areas


Water carts and vacuum sweeping of sealed roads assist with the reduction of traffic-generated dust emissions

Vegetative stabilization of bare areas to reduce the generation of wind-blown dust emissions






non-compliance *


Fixed sprays in some areas where materials are stockpiled

Backup systems (water supply and pumps)

Truck and wheel wash facilities to help reduce the drag-out of particles onto sealed roads from vehicles exiting un-sealed areas of the site



Written Procedures

Maintenance schedule on plant and equipment

Monitoring and reporting system for dust emissions

Training

Managing Major Environmental Pollution Incidents

Yes Procedures, processes and equipment for managing major environmental pollution incidents

The licensee has procedures, processes and equipment in place to manage major environmental incidents. The procedures include;

Documentation systems and procedures within the Emergency Response Plan to deal with all types of incidents and keeping the Plan onsite - Please refer to Further Observations






non-compliance *


Evacuation of non-essential personnel and notification to Senior Licensee management

Notification to relevant agencies such as NSW Fire Services, Port Kembla Port Corporation (including Port Kembla Marine Oil and Chemical Spill Contingency Plan)

Notification to the impacted community

Staff training in emergency response procedures

Assigning roles and responsibilities to key personnel

Availability of emergency response equipment

Drills, simulations – yes – once a year a live drill involving a realistic scenario is performed (e.g. power failure on spare charger car).

Environmental incident/complaint and response procedures in place, including regular discussions with Regulators

Check list of responsibilities and roles for Emergency Management Team

M MONITORING CONDITIONS

The audit assessment is based upon evidence relating to the period limited to 12 months prior to the end of the audit inspection. M6.1, M6.2 & M6.4

Yes Recording of pollution complaints

The licensee keeps a detailed record of complaints made to the licensee arising from any activity to which this licence applies and produced a sample at the request of the auditors.

M6.3 It is beyond the scope of the audit to determine whether the licensee retains the records for at least 4 years.

The licensee has records of complaints made in the past and the EPA has no reason to believe that those records would not be kept for the required 4 years.






non-compliance *


M7.1 Yes Operating a telephone line for receiving complaints

The licensee operates during its operating hours (24 hours per day/7days a week) a telephone line for the purpose of receiving any complaints from members of the public.

M7.2 Yes

Advertising the telephone complaints line number to the public

The licensee operates during its operating hours a telephone complaints line for the purpose of receiving any complaints from members of the public.

It was noted on the day of the audit that the site contact number was advertised at the electronic white pages (www.whitepages.com.au), and it did state that the number was an environment complaints hot line.

M7.3 This is a deeming clause that determines the applicability of Conditions M5.1-M5.2 and no assessment of compliance is required. It is noted that M5.1 and M5.2 do apply as the licence was been issued for more than 3 months.

R REPORTING CONDITIONS

The audit assessment is based upon evidence relating to the period limited to 12 months prior to the end of the audit inspection. R2.1 & R2.2 Yes

Notification of environmental harm

These requirements did apply as there were major environmental incidents causing or threatening material harm to the environment which occurred within the scope of the audit. The licensee reported over 40 incidents to the environment line in the last 12 months. A sample was taken from a range of recent incidents and these were reviewed during the audit.






non-compliance *


U POLLUTION REDUCTION PROGRAMS

The audit assessment is based upon evidence relating to the period limited to 12 months prior to the end of the audit inspection. U15 (Part A) Yes

PRP 149 Coke Ovens Gas Mains Solids Management

Note: The licensee previously identified the storage of COG residues as an activity with a high environmental risk. Part A of this condition referred to the Coke Ovens Gas Mains Solids stockpiled at the premises and required a report to be submitted to the EPA by 28 February 2011.

The licensee presented EPA with a written report by the due date that:

Identified and reviewed the technically feasible options for the appropriate storage

and/or treatment and/ or disposal of the Coke Ovens gas mains solids.

Provided a cost/ benefit analysis of the feasible management options.

Nominated the preferred management option/s

Provided the expected implementation timeframe for the preferred option/s.

(The EPA requested some additional information for inclusion in the Part B report).

U15 (Part B) Not determined Part B of this condition required the preparation of a Management Plan. The licensee presented EPA with a management plan by the due date of 31 July 2011. The licensee’s report is still under review by Illawarra Office of the EPA.



Tank with corrosion repair and also showing spillage and/or leak residue on the compacted slag base below the site of the corrosion repair



3.0 FURTHER OBSERVATIONS

Further observations are recorded where the audit identified issues of environmental concern which do not strictly relate to the scope of the audit or assessment of compliance. Further observations are considered to be indicators of potential non-compliances or areas where environmental performance may be improved.

Further Observation No.1 - Loss of containment of tar in the Gas Holder area, and possible migration to the Main Drain and into the harbour

During the audit inspection a floating sheen was observed on the surface of the liquid flowing in the drain adjacent to the Gas Holders and tar spatter was observed on surfaces beyond the collection pit. The licensee advised that the source of the tar was from leakages through the walls of the gas holders.

The EPA is concerned that on-site water pollution occurring as a result of the management of the gas holders and surrounding area is not being minimised as a result of the absence of adequate at-source control measures.

The EPA is also concerned that the pathway causing the escape of tar through the walls of the gas holders is also a potential pathway for the loss of containment of coke ovens and blast furnace gases from within the storages to the atmosphere. This being the case, the licensee should evaluate the gas leakage and the environmental impact.

Note: The licensee did not identify loss of containment from the gas holders as a high environmental risk, unlike the safety, plant and outrage risks.

Further Observation No.2 – Liquid (Water) discharge from areas around the BOS Furnaces (including Waste water Treatment Plant and Slag Yard) with the potential to go to Allen’s Creek.

During the audit inspection a stockpile of loose material was observed on the eastern side of Allan’s Creek Road (see photograph).

The EPA is concerned about the potential for material in the stockpile to be washed into Alan’s creek.

During the audit inspection the EPA also made two other observations where the licensee should examine opportunities to improve the control over releases of contaminated stormwater to the harbour:

(a) There appears to be transport of sediments from bare areas in stormwater from the area of the old No. 4 blast furnace to a grated field entry drain. The grate was marked to indicate that flows would enter the Port Kembla Harbour.



(b) Allan’s Creek Road passes between the western end of the raw materials handling plant and a concrete barrier on the edge of the mouth of Allan’s Creek. The barrier has pipes to release stormwater to the mouth of Allan’s Creek. The accumulation of sediments around, and in these pipes increases the likelihood for the pollution of waters.

While there has been a number of PRP’s aimed at improving the quality of stormwater discharges, the EPA is concerned about the level of pollution control being installed at the sites mentioned above.

Stockpile of loose material on the side of Allan’s Creek Road, with Allan’s Creek in the background

Further Observation No.3 – Procedures, processes and equipment for managing major environmental pollution incidents

The Coke Making Department Emergency Plan (MA-CB_EME-01-01) contact telephone number for the Environment Department is shown as 6970. The purpose of this contact number is for the Coke Making Department’s emergency controller to notify the licensee’s Environment department to initiate their plan, take samples from drains and notify EPA. However the contact number provided in the Emergency Plan is incorrect. The EPA also notes that there is a backup pathway in the Emergency Response Plans for contacting the licensee’s Environment department that relies on the security contractor. The EPA has no reason to believe that the security contractors’ contacts are not being kept up to date.

The EPA is concerned that contact details in the Coke Making Department Emergency Plan is not being maintained which could result in unnecessary delays in implementing the emergency response plan.



4.0 ACTION PROGRAM

The following action program must be undertaken in relation to BlueScope Steel (AIS) Pty Ltd.

Table 4.1 Action Program – Environment Protection Licence No. 6092

Condition

No. Action Details Non-Compliance

Code (where applicable)

Target/Action Date

O1.1 The licensee must implement controls and monitor the effectiveness of those controls to minimise the likelihood of discharge of stored COG main residues from the site.

Code Red 30 June 2012

EPA considers that the licensee should take the necessary actions to ensure that environmental performance is improved in relation to any matters identified as a Further Observation in Section 3.0 of this Report.


APPENDIX A

LICENSEES RESPONSE TO DRAFT REPORT

APPENDIX B

LETTER COVERING LICENSEES RESPONSE TO DRAFT COMPLIANCE AUDIT REPORT

Final compliance audit report: Bluescope Steel Pty Ltd · FINAL COMPLIANCE AUDIT REPORT BLUESCOPE...

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