QENOS PTY LTD
Annual Report on Manufacturing Operations at Qenos Olefins,
Plastics, Resins and Elastomers Sites to Altona Complex
Neighbourhood Consultative Group April 2004
CONTENTS
CONTENTS
1
SUMMARY
2
INTRODUCTION
3
SAFETY HEALTH and ENVIRONMENT (SH&E) POLICY & CHARTER
4
2003 AUDIT PROGRAM
6
SH&E MANAGEMENT SYSTEM
7
COMMUNITY COMPLAINTS
7
ENVIRONMENTAL INCIDENTS
8
EPA WASTE DISCHARGE LICENCES
9
CITY WEST WATER TRADE WASTE AGREEMENT
12
PRESSURE SAFETY VALVE ISSUES
13
NOISE ABATEMENT
14
WASTE REDUCTION PERFORMANCE MEASURES
15
SOLID & EPA PRESCRIBED WASTES
17
ENERGY EFFICIENCY & GREENHOUSE GASES
18
GROUNDWATER MANAGEMENT PLAN
19
ENVIRONMENT IMPROVEMENT PLAN (EIP)
20
COMMUNITY RIGHT TO KNOW & COMMUNITY INTERFACES
21
PERSONAL SAFETY PERFORMANCE
22
HEALTH INITIATIVES
23
MAJOR HAZARD FACILITIES (MHF) REGULATIONS
24
SH&E INCIDENT SUMMARY
27
Annual Report to ACNCG, 2004
Page 1
QENOS PTY LTD
SUMMARY
In 2003, production at Qenos was again steady following the return to normal rates the
previous year.
Highlights of performance this year are:
•
achieving environmental accreditation of the Resins site and re-accreditation of the
other three sites;
•
the Elastomers plant passed 3 years without a community complaint or a Trade
Waste noncompliance;
•
the Plastics site recorded 3 years without a reportable incident;
•
reduction in emissions of the Class 3 indicator, butadiene, by 30%
•
connection of the Spent Caustic Carbonation system tail gas to the boilers to avoid
generation of highly odorous spent catalyst, and the removal of the spent catalyst
from one of the two reactor beds
•
completion of 16 noise reduction projects at Plastics two years ahead of plan
•
implementation of the WasteCert electronic waste transport certificate system
•
redirection of Elastomers plant effluent to the Plastics waste water treatment plant
•
pressure safety valve lifts at Olefins decreased by more than 50%
•
removal of soil stockpiles from Olefins site
•
installation of new flare tip at Olefins
•
completion of sewer inspection at Olefins, and development of a routine sewer
inspection plan
•
completion of the Olefins environmental performance review and progressing the
recommendations from this
Areas for improvement are:
•
continuing to address means of reducing incidents and community complaints at the
Olefins site
•
working to reverse the increase in the number of injuries to contractors
Annual Report to ACNCG, 2004
Page 2
QENOS PTY LTD
INTRODUCTION
In July 1999, Orica Limited and Kemcor Australia Ltd combined their polyethylene,
polypropylene, synthetic rubber and engineering plastics operations into a new joint venture,
Qenos Pty Ltd.
Qenos Pty Ltd is owned equally by ExxonMobil and Orica and operates plants in Sydney and
Altona.
This annual report addresses the year 2003 operations of the four manufacturing sites at
Altona, Qenos Olefins, Qenos Plastics, Qenos Resins and Qenos Elastomers.
Figure 1
Total production, kt
1000
500
673
700
691
532
549
556
353
0
1997 1998 1999 2000 2001 2002 2003
Total production across all the sites in kilotonnes is shown in Figure 1. This is based on
production of hydrocarbon intermediates that are transferred to other plants as well as
production of final products for sale.
Production was normal in 2003 with few interruptions to operations.
Qenos Olefins
Qenos Olefins uses ethane gas from Bass Strait and gas oil liquid from the Mobil Altona
refinery to produce ethylene and propylene (used to manufacture plastics) and butadiene (used
to manufacture synthetic rubber). Two byproducts (gasoline and gas oil tar) are also produced.
Qenos is still reviewing conversion of SCAL 1 from gas oil feedstock to a gaseous feedstock.
Qenos Plastics
Qenos Plastics uses ethylene from the Olefins site to manufacture polyethylene. The lowpressure polymerisation plant produces high-density polyethylene (HDPE) used for products
such as milk bottles, irrigation and gas piping and household containers.
Qenos Resins
Qenos Resins also produces HDPE from ethylene manufactured by Olefins but by a different
process from Qenos Plastics. The HDPE from Resins is used in a similar range of products to
that from Plastics, but especially for Mobile Garbage Bins.
Polypropylene is also produced at Resins from propylene manufactured by Olefins.
Polypropylene, a harder plastic material than HDPE, is used in the manufacture of films, tapes
and injection moulded products eg. food containers.
Annual Report to ACNCG, 2004
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QENOS PTY LTD
Qenos Elastomers
Qenos Elastomers manufactures polybutadiene rubber (BR) by the polymerisation of
butadiene in a solution process. The major feedstock, butadiene is supplied by the Olefins
site. Qenos Elastomers is the only producer of synthetic rubber in Australia and the
products are supplied to a wide range of industries with the tyre industry as the major
customer.
SH&E POLICY & CHARTER
Qenos SH&E POLICY
Qenos has a combined Safety, Health and Environment Policy to match the integrated
approach in its Safety, Health and Environment Operating System (SHEOS). This Policy
incorporates the best aspects of policies from shareholders, and includes reference to
Responsible Care. The Policy is as follows:
At Qenos, we believe that all injuries, occupational illnesses and environmental incidents
are preventable.
We are committed to, and everyone who works at Qenos must show responsibility for,
operations, products and practices that protect the safety and health of our employees,
contractors, customers and the community, as well as protecting the environment.
This is more than another element in our business competing for priority; it is an absolute
requirement.
We will:
•
strive for a workplace that is free from injury, illness and incident
•
encourage employee initiatives that contribute to a safe and improved environment
at work, home and in the community
•
minimise risks associated with the manufacturing, transportation, use and disposal
of our products
•
anticipate, analyse and discuss risks with those affected, and monitor events to
ensure proper control
•
conduct all operations and market all products with adequate safeguards
•
be prepared for emergencies, responding quickly and effectively to incidents
resulting from our operations
•
efficiently use materials and energy, and dispose of wastes in a safe and
environmentally sound way
•
continuously improve our safety, health and environmental performance through
effective management systems, measurements and targets
Annual Report to ACNCG, 2004
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QENOS PTY LTD
•
expand our knowledge of safety, health and the effect of our operations on the
environment, and share this knowledge with others
•
strive to be a trusted and responsible member of the community through
performance, full and open communication, and involvement
•
work with others to develop responsible laws, regulations and standards, based on
sound science and assessment of risks, as required to further safeguard the
workplace, community and environment.
These commitments are in addition to our basic intent to comply with all safety, health and
environmental laws, regulations and Responsible Care requirements.
Risk: identify it, assess it, control it.
In addition, all employees are asked to sign a Safety, Health and Environment Charter. The
Charter sets out accountabilities for all employees and line managers.
SH&E CHARTER
Everybody
•
Learn and follow all SH&E requirements related to the job
•
Maintain SH&E awareness in all tasks, preventing injuries, illnesses or safety or
environmental incidents
•
Maintain a clean and orderly work area at all times
•
Constantly review the workplace for hazards which could lead to injury, illness or
incident and initiate appropriate corrective actions
•
Report to work fit for duty without impairment from alcohol, drugs, medications or other
influences
•
Address improper SH&E practices observed in co-workers including contractors
•
Look for opportunities to improve SH&E performance and actively participate in SH&E
improvement activities
•
Immediately report all injuries, illnesses and safety and environmental incidents
•
If ill or injured, actively participate in rehabilitation programs to promote recovery.
Annual Report to ACNCG, 2004
Page 5
QENOS PTY LTD
Line Managers
•
Clearly communicate the vision and Expectations and keep SH&E as the top priority in
all decisions, actions and communications
•
Provide leadership for the development and implementation of SH&E plans
•
Ensure that rules and procedures for preventing all SH&E incidents in your work area
are in place and are enforced
•
Lead by example by setting high SH&E standards, following rules, procedures, and
using good work practices
•
Know the SH&E requirements of the job performed by the people you lead and ensure
they are appropriately trained
•
Audit work practices frequently and do not tolerate any deviations from required
standards, addressing any known SH&E non-conformance or opportunity for
improvement with appropriate priority
•
Ensure that all contractors are managed or supervised to the same standards as
Qenos employees
•
Create an environment of openness, trust and mutual respect which allows everybody
to excel and be recognised for good SH&E performance
•
Participate in investigation of SH&E incidents and ensure that recommendations to
prevent recurrence are followed through to completion
•
Promptly arrange rehabilitation for an ill or injured employee, providing full support for
them and their family.
2003 AUDIT PROGRAM
The 2003 audit program included internal reviews of the Qenos Safety, Health and
Environment Operating System (SHEOS), waste contractor self-auditing with spot checks
by Qenos, a Regulatory Compliance audit of Elastomers, and external auditing by the EPA
appointed auditor.
The EPA Appointed Environmental Auditor conducted an audit to cover Elastomers,
Olefins, Plastics and Resins, focussing on performance, environmental risk assessment and
communication with the community as well as ensuring the Accredited Licensee scheme
requirements were in place at Qenos. The Auditor highlighted the elimination of the
odorous residues from the Spent Caustic Plant by directing the tailgas to the boilers and the
reduction of Class 3 indicators to atmosphere by a more focussed Leak Detection and
Repair program. The report, which confirmed that the Accredited Licensee criteria were
satisfactorily met, has been given to the Victorian EPA separately. An audit of Solid Waste
Management supervised by the EPA accredited auditor was included in that report.
SH&E MANAGEMENT SYSTEM
Annual Report to ACNCG, 2004
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QENOS PTY LTD
An internal assessment audit of the SH&E Operating System(SHEOS), which incorporates
the Safety Management System, Environment Management System and Responsible Care
requirements confirmed continuing improvement in our SHEOS, during 2003. The long
term continuing improvement of the SHEOS is shown in Figure 2.
The average rating for the 21 practices within SHEOS for 2003 was 3.7 (out of a possible
4.0.), which was an incremental improvement on our average rating of 3.6 for the 2002
external assessment by ExxonMobil personnel from around the world.
Figure 2
Altona SHEOS Improvement History
4
3.5
3
Qenos
External
2.5
2
1.5
1995
1996
1997
1998
1999
2000
2001
2002
2003
Year
COMMUNITY COMPLAINTS
Unfortunately the record breaking low number of complaints received in 2002 was not
sustained in 2003 as shown by Figure 3.
20 of the community complaints received related to odour, mostly caused by an incident that
resulted in storage of effluent in the Stormpond at Olefins. Improvements to the Effluent
Treatment Plant and elimination of an odorous residue should result in lower impact on our
neighbours by the end of 2004.
17 complaints were about flaring at Elastomers, Olefins and Plastics. The Olefins flaring was
mostly due to two major compressor trips. The Plastics flaring was due to loss of power
supply, a matter which has been taken up with our power company, and is likely to show
improvement due to the installation of new equipment in the first half of 2004.
2004 has started on a much improved note with zero complaints for the first two months.
Annual Report to ACNCG, 2004
Page 7
QENOS PTY LTD
Figure 3
Community Complaints
70
66
66
59
60
50
39
40
32
41
39
27
30
19
16
01
02
20
10
0
94
95
96
97
98
99
00
03
ENVIRONMENTAL INCIDENTS
The following incidents were reported in accordance with the agreed Leak and Spill reporting
procedure. All have been discussed at past ACNCG meetings.
ELASTOMERS SITE
There were no reportable incidents on the Elastomers site in 2003.
OLEFINS SITE
There was an improvement in the number of reportable incidents on the Olefins site during
2003, the number dropping from eight to seven. These are summarised below:
7/01/03
Olefins
20/01/03
Olefins
8/02/03
Olefins
16/04/03
Olefins
12/06/03
Olefins
5/08/03
Olefins
14/10/03
Olefins
Heavy flaring following Scal-2 charge gas compressor, C-701, trip due to faulty
vibration sensor. Scal-1 C-352 also tripped when Scal-2 went down. 4
complaints made this a reportable incident.
Loss of containment of 1400kg of hypochlorite during transfer from one tank to
another. Contained in a bund so no environmental damage. Reported to
WorkSafe and EPA.
Loss of containment of 12000kg of sulphuric acid when pinhole developed in
manhead weld on TK969. All acid was contained in the tank bund, and
recovered for use.
Loss of containment of up to 5000 kg of sulphuric acid from temporary road
tanker when plug in outlet line failed. Most of the acid flowed into the dirty
water sewer and was neutralised prior to discharge. Some flowed outside the
bund across stones into the clean water sewer, but was contained to the area
and neutralised in-situ.
PSV discharge to atmosphere of 50kg Benzene and 70kg Butadiene from T681 PSV following Scal 2 trip after cooling water failure.
Heavy flaring following Scal-1 loss of lean oil flow when bringing T209A on line,
and subsequent trip of three compressors. Exceeded smokeless capacity, with
heavy smoking for 30-60 minutes. Total of 5 complaints made this a reportable
incident.
Odour from quench oil on surface of storm pond following ETP oil
breakthrough. 3 complaints on first night and one the next day make this a
reportable incident. Total of 7 complaints over 5 days.
Investigations were carried out for each incident and follow-up actions identified. Full details of
these incidents were issued to EPA and the ACNCG at the time of the incident.
Annual Report to ACNCG, 2004
Page 8
QENOS PTY LTD
A review, including input from the Accredited Licence auditor, was conducted in the first half of
the year and the second half of the year shows a marked reduction in the number of incidents.
The recommendations from the review have been incorporated into the Environment
Improvement Plan.
PLASTICS SITE
There were no reportable incidents at the Plastics site in 2003.
RESINS SITE
There were 3 reportable incidents at the Resins site in 2003.
21/01/03
Resins
11/04/03
Resins
27/05/03
Resins
Particulate. Release of 200-500kgs of polypropylene powder from the FBD
was carried to Prixcar. Washing of cars was paid for by Resins. Root cause
appears to be plugging of cyclone not recognised by operator.
Loss of containment of 18m3 (14000kg) of Exxsol D30 solvent when pump left
running and overfilled sludge tank. The solvent flowed into drains which flowed
back into the sludge pit, so spill was fully contained.
Loss of containment of approximately 1.5 tonnes of propylene from R29 when
manhead gasket failed. Emergency services and regulators were notified and
emergency procedures activated. An investigation was undertaken with the
participation of an ACNCG member.
EPA WASTE DISCHARGE LICENCES
Table 1 shows a comparison of the estimated emissions from the Olefins, Elastomers, Plastics
and Resins sites with the discharge limits specified in the EPA licence. There are no
exceedances.
In 2003,the Accredited Licence was renewed for Elastomers, Olefins and Plastics, and Resins
was added.The increases in emissions of particulates, hydrogen chloride and Total Organic
Compounds emissions are due to the addition of Resins discharges to those from the other
sites.
Annual Report to ACNCG, 2004
Page 9
QENOS PTY LTD
Table 1:
Qenos Performance compared with EPA Licence:
Compound
EPA bubble
licence, tpa
or gm/min
Ammonia
Benzene
Butadiene
Cyclohexane
Carbon
monoxide
Hydrogen
Chloride
Nitrogen Oxides
Particulates
12
15
45
15
811 gm/min
Styrene
Sulphur dioxide
Total Organic
Compounds
2000
emissions,
tpa or g/min
(excludes
Resins)
10.1
7.9
22.0
10.5
660 gm/min
(peak rate)
2001
emissions,
tpa or g/min
(excludes
Resins)
6.4
7.7
11.8
6.5
660 g/min
(peak rate)
2002
emissions
tpa or g/min
(excludes
Resins)
6.4
6.6
31.4
6.5
660 g/min
(peak rate)
578
175 gm/min
459
76 gm/min
(peak rate)
456
76 g/min
(peak rate)
462
76 g/min
(peak rate)
5
440
1500
19.9
134
496
1.0
119
317
0.5
124
380
4.4 gm/min
2003
emissions,
tpa or g/min
(includes
Resins)*
6.4
5.9
20.4
6.3
660 g/min
(peak rate)
< 0.1 g/min
( Nil)
477(458)
116 g/min
(peak rate)
(76)
0.4
142**
709(328)
* For comparison with previous years, figures in brackets refer to emission levels from
Elastomers, Olefins and Plastics only.
**The increase in Sulphur Dioxide emissions was due to direction of the Olefins Spent
Caustic tailgas to the boilers, which enabled Olefins to stop generation of a highly odorous
solid waste. The waste has caused many community complaints in the past.
Annual Report to ACNCG, 2004
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QENOS PTY LTD
Table 2 shows a comparison of the results of water discharge at the Qenos Plastics site with the discharge limits specified in the EPA licence.
Testing showed compliance with licence limits.
Plastics Effluent Monitoring Summary, 2003
PLASTICS WASTE WATER DISCHARGE TO LAND ( IRRIGATION / DAM )
2003
Month :
Jan
Feb
Mar
Apr
May
Jun
Volume ( m3 )
Licence Requirement :
Weekly discharge
volume : 10,000 m3
2907
1846
33
6002
2392
Total
Jul
5959 12792
Aug
7265
Sep
Oct
Nov
11394 11900
Dec
21267 18929 102,686
Yearly discharge volume : 220,000 m3
PLASTICS WASTE WATER MONITORING RESULTS 2003
Month :
BOD
Suspended Solids
E. Coli
Dissolved Oxygen
pH
Annual Report to ACNCG, 2004
Page 11
Jan
Feb
Mar
Apr
Licence
May
Jun
Jul
Aug
Sep
Oct
Nov
2
<2
<10
<2
3
<10
7
8
<10
2
7
<10
4
10
<10
2
2
0
10
66
0
22
39
2
<2
7
0
<2
5
0
4
11
<10
10
8
8.1
7.9
8.5
8.3
9.7
8.3
8.9
8
8.4
8
8.2
7.8
8.3
7.8
8.3
8
8
8
7.7
7.6
Dec
<2 <40 mg/L
21
<80
<10 <400,000
org/100
mL
7.5 >5mg/L
7.8 6.0 - 9.0
QENOS PTY LTD
EPA LICENCE NON-CONFORMANCES
There were 3 instances of noncompliance with Qenos’ EPA licences in 2003:
Olefins
Smoking F655 Furnace Stack - following C-701 trip, furnace feed rates were dropped
quickly, fuel to furnace mistakenly adjusted wrong way leading to fuel rich firebox and
resulting smoke. Ringlemann 3 for 1 minute, exceeded SEPP allowance.
Elastomers Smoking flare - exceeded allowance of five hours of smoking for 2003. (Majority from
D359 overpressure incident of 29/3/03). May incident due to ethane-rich fuel gas in flare
header smoking when displaced to flare by nitrogen during normal tank filling operations.
Elastomers Hole found in effluent line, discharging effluent to land on-site. No pollution concerns,
however this is a technical breach of licence.
CITY WEST WATER TRADE WASTE AGREEMENT
Waste minimisation is a requirement of the Agreement and this is achieved through the EIP.
However, Qenos is stewarded by the ACNCG and CWW on the total effluent to sewer as well
as the traditional wastes and emissions.
Sewer discharge volume relative to production is shown in Figure 4
Figure 4
Total Waste to Sewer ML / kt production
5
4.0
4
3
3.2
3.0
2.7
3.0
3.0
2.9
2
1
0
1997
1998
1999
2000
2001
2002
2003
Sewer discharge volumes for Olefins and Elastomers were down on last year by over 5% due
to a number of water reduction projects being implemented during the year. At Olefins
condensate recovery facilities were improved to reduce the amount of hot condensate going to
sewer. In a co-operative approach from CWW, the Trade Waste Agreement was varied to
allow short duration discharges up to 42°C so that Olefins could run effluent closer to the
normal spec of 38°C without risk of a licence breach if the temperature spiked a couple of
degrees. This has allowed a very significant reduction in the amount of cooling water required
to meet the spec. Also, effluent from the Elastomers plant, which is quite clean now that SBR
is shut down, has been redirected to the Plastics plant where there was excess capacity in the
on-site Waste Water Treatment Plant following the closure of the HPPE plant. This treated
effluent is now used for cooling water make-up rather than being discharged to CWW sewer as
trade waste. These changes were made towards the end of 2003, so the full benefit is not
reflected in the 2003 figures, but should appear in the 2004 results.
Annual Report to ACNCG, 2004
Page 12
QENOS PTY LTD
The effluent cooling heat exchangers at Olefins do not provide sufficient cooling to eliminate
the need to use cooling water. One of these exchangers failed towards the end of 2003, so
this is being viewed as an opportunity to replace it with a similar unit but with greater capacity to
ensure lo wer effluent temperatures. The replacement is expected during 2004.
CWW Trade Waste Agreement Non-conformances
The following incidents have been fully reviewed with the EMT.
Olefins 3/2/03
The Combined Final Effluent sample tested 1.8 mg/l for sulphides, versus a spec limit of 1.0
mg/l. The Nutriox addition pump was found stopped. Pump restarted and sample retested
shortly after, and back in spec. A low flow alarm has now been incorporated into the Nutriox
addition facilities.
Olefins 4/6/03
Combined Final Effluent sample collected by CWW was tested at 180 mg/l ammonia,
versus a spec limit of 50 mg/l. Investigation revealed the drain rate of treated blue water
from TK964 had been inappropriately increased on the preceding night shift. This had been
put back to normal flowrate by the dayshift team by the time this sample was collected.
Resins 28/7/03
Effluent sample collected by CWW tested 3.0 mg/l for Exxsol D30 solvent, versus a spec
limit of 2.0 mg/l. No specific event was identified to cause a high solvent level. A program to
determine typical solvent levels is underway.
Olefins 14/10/03
Free oil was discharged to the CWW sewer. Excessive oil accumulation due to a bad pump
seal and poor operation of oil removal facilities in the Olefins Effluent Treatment Plant had
lead to a breakthrough of oil into the final effluent stream. The ETP is being opened for a
full clean out, and operating practices and procedures are being reviewed. The leaking
pump seal is being replaced with a different design that will not put oil to sewer
PRESSURE SAFETY VALVE AND HIGH PRESSURE ALARM
PERFORMANCE
Implementation of the final report of the Pressure Management Review Committee
continued in 2003.
Olefins focus is on ensuring stable operations to continuously reduce the SV lift frequency,
and the decrease in lifts by 30% was a significant achievement. Of the 47 lifts, 24 arose
from abnormal incidents; a power dip, cooling water failure and a compressor trip.
During 2003, there were 53 pressure safety valve lifts across all the Qenos sites,
significantly lower than the 75 recorded for 2002. Seventeen of these resulted in discharge
of hydrocarbons to atmosphere.
Annual Report to ACNCG, 2004
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QENOS PTY LTD
Table 3 – PSV lifts by site
Site
Olefins
Elastomers
Plastics
Resins
No. of PSV Lifts
2002
2003
67
47
0
4
2
0
6
2
NOISE ABATEMENT
Environmental noise data continued to be collected from the noise meter located at Charles
Road, within one of the closest residential areas to the Complex. The noise meter is
connected by a microwave link to a computer at the Plastics site.
During 2000 a new basis for the analysis and reporting of noise levels was developed. This
method uses noise levels measured under a set of standard conditions as the indicator of
Qenos’ progress in reducing background noise from Olefins and Plastics.
The parameter measured by the meter is LA90, or the noise level that is exceeded 90% of
the time, over a long period. The LA90 gives a better indication of background noise levels
because it filters out peaks caused by short-term noise sources eg. nearby passing cars or
wildlife.
The LA90 measured at Charles Road is related closely to the wind direction and speed.
LA90 data collected when the wind is blowing towards the noise meter from the Complex, at
between 2 and 4 metres per second and between the hours of 10 pm and 6 am will be used
as a measure of Qenos’ progress in reducing plant noise. There was a slight adjustment to
widen the angle of the relevant wind data in May 2002 as it was felt that some Qenos
sources may not have been captured by the previous settings. Qenos has a target of a
2.5dBA reduction in noise over a 5 year period due to noise abatement measures at the
major noise sources within the Olefins and Plastics site.
The shutdown of the Olefins and Plastics plants towards the end of 2000 due to industrial
action provided a unique opportunity for the collection of noise data at Charles Road without
the inclusion of noise from Qenos’ plants. As can be seen from Figure 6 the average LA90
without the plants operating and at the standard conditions was approximately 50 dBA, 5
dBA less than that observed while the plants were operating. This demonstrates that the
target of a 2.5dBA reduction is significant. In fact, current levels are averaging close to the
52.5dBA level
There were technical problems after the noise meter was sent for a calibration test in
October 2002, and useable data was not retrieved until February 2003. A step change
downwards was noticed following this, with monthly average noise levels in the 49 - 51 dBA
range, whereas they had previously been around 52 –53 dBA. A subsequent calibration
check was performed in December 2003, and results since may have stepped back up to
the 51 –52 dBA range.
A total of 16 noise reduction projects were completed at the Plastics site in 2003, well ahead
of their scheduled due date of June 2005.
Annual Report to ACNCG, 2004
Page 14
QENOS PTY LTD
Figure 5
Noise at the Charles Rd noise meter under standard conditions
(Between 10 pm and 6 am, wind direction 265-285°, (265-323° from May-02), wind velocity 2-4 m/s)
60.00
58.00
Plants shut
down
Incomplete data due to technical
problems with software
Problems with noise
meter following
calibration/service
Wind direction increased to
o
265-323 from May 2002
Meter calibrated
mid Dec 2003
56.00
54.00
52.00
50.00
48.00
46.00
44.00
Feb-04
Dec-03
Oct-03
Aug-03
Jun-03
Apr-03
Feb-03
Dec-02
Oct-02
Aug-02
Jun-02
Apr-02
Feb-02
Dec-01
Oct-01
Aug-01
Jun-01
Apr-01
Feb-01
Dec-00
Oct-00
Aug-00
Jun-00
40.00
Apr-00
42.00
WASTE REDUCTION PERFORMANCE MEASURES
VOLATILE ORGANIC COMPOUNDS (VOCs)
Total VOC emissions to the atmosphere from the Qenos sites are shown in Figure 6. VOCs
include ethylene, propylene, propane, butadiene, ethane, styrene, benzene and mineral
turpentine.
Figure 6
VOC Emissions
Resins
3500
22002250
3000
2500
Olefins,
Plastics,
Elastomers
2000
1500
1000
0
625
416
271 331381
500 1080776 662 437 496 317 380 328
0
93 97 98 99 00 01 02 03
Annual Report to ACNCG, 2004
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QENOS PTY LTD
Figure 7
VOC tonne/kt production
6.0
4.0
2.0
0.0
4.4
4.2
1.7
1.5
1.7
1.3
1.3
1997 1998 1999 2000 2001 2002 2003
Year
VOC emissions from the four sites decreased slightly in 2003, despite an increase in
production.
Efforts to reduce VOC emissions are focused on reducing emissions of the Class 3 indicators,
benzene and butadiene, as a priority. In 2003, Qenos submittted a plan to reduce emissions of
Class 3 indicators, especially butadiene, which became a Class 3 indicator in 2002 . The plan
is to give priority to pipes carrying process streams containing benzene and butadiene in
identifying and repairing leaking valves. While the threshold value above which the EPA
requires the valve to be repaired is 10000ppm, Qenos has dropped the threshold to 200ppm
for streams containing Class 3 indicators. This is equivalent to world’s best practice.
Figure 8 shows benzene emissions to air. Benzene emissions dropped slightly to a record low
level despite the increase in production.
Figure 8
Benzene Emissions - Tonnes
27
30
25
20
15
10
5
0
18
13
93
97
98
7
8
8
7
6
99
00
01
02
03
Butadiene emissions, shown in Figure 9, were reduced to a record low level(except when the
Butadiene Extraction unit was shut down for most of 2001) in 2003, due to institution of the
more stringent Leak Detection and Repair program. This resulted in repair of a number of
valves that may have been leaking because of a prolonged shutdown in 2001.
Figure 9
Butadiene Emissions - Tonnes
150
128
100
48
50
22
21
22
12
98
99
00
01
31
20
02
03
0
93
Annual Report to ACNCG, 2004
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97
QENOS PTY LTD
Styrene emissions to air are shown in Figure 10. The main source of styrene emissions
was the SBR dryer at Elastomers. With the closure of the SBR plant styrene emissions
have been almost eliminated. A small source of styrene remains as part of the Olefins
process.
Figure 10
Styrene Emissions -Tonnes
47
50
40
27
30
25
23
20
20
10
1
0.5
0.4
01
02
03
0
93
97
98
99
00
SOLID AND EPA PRESCRIBED WASTES
Total EPA prescribed wastes and non prescribed wastes (general wastes) transported from
Qenos are shown in Figures 11, 12 and 13. The total waste transported off site in 2003 was
slightly lower than 2002, reflected by a reduction in the waste per unit production (see Fig
13) although there was an increase in prescribed waste.
F ig u re 1 1
T o ta l P r e s c rib e d W a s te - T o n n e s
1 2 0 0 0
1 0 0 0 0
1 0 0 0 0
8 0 0 0
6 0 0 0
3 3 6 0 3 1 2 3 2 8 3 6 2 8 9 4
4 0 0 0
1 7 6 5
2 4 6 6 2 5 7 6
2 0 0 0
0
9 3
9 7
9 8
9 9
0 0
0 1
0 2
Note: Figures since 1997 include the Resins site.
F ig u r e 1 2
T o ta l G e n e r a l W a s t e - T o n n e s
1500
1116
963
1134
994
1167
1000
677
750
01
02
515
500
0
93
Annual Report to ACNCG, 2004
Page 17
97
98
99
00
03
0 3
QENOS PTY LTD
Figure 13
Total Solid Waste Tonne/kt Production
8.0
6.0
6.4
7.6
6.1
6.9
5.5
5.9
5.6
4.0
2.0
0.0
1997
1998
1999
2000
2001
2002
2003
The Resins Solid Liquid Separator powder waste stream, amounting to 2-300 tonnes, was
reclassified from general to prescribed waste, explaining the significant reduction in general
waste this year, and the corresponding increase in prescribed waste. We are exploring
opportunities for potential markets for this waste.
The project to eliminate the sulfatreat catalyst beds in the Olefins Spent Caustic Carbonation
unit by redirecting the tail gas into the boilers was implemented early 2003. One of the two
catalyst beds has been emptied with the remaining bed scheduled for mid-2004. Once
emptied, Olefins will no longer produce this waste stream, eliminating about 100 tonnes per
year of highly odorous solid waste.
The Collex project to convert some wastes into fuel briquettes has progressed, with trials
completed successfully, and the Works Approval submitted to EPA. Selection of the
briquetting machine is underway, and Collex expects construction to begin before mid-year,
with commissioning in 3Q. Minister for the Environment, John Thwaites, presented Collex with
an award for the first project under the Business Energy Innovation Initiative on March 21,
2004. Potentially, up to 50% of Qenos’ solid prescribed waste can be converted to fuel in this
process, thereby removing the need to send these wastes to secure landfill.
Two byproduct streams produced at the Resins site, polyethylene wax and powder collected
from the Solid Liquid Separator, are currently disposed of to prescribed waste landfill. Both
streams can go to the briquetting process when it becomes available, however recent work has
identified potential markets for these materials, and it is expected that both will soon be
saleable products. Together, these streams comprised 950 tonnes of prescribed waste to
landfill in 2003, or 96% of Resins total prescribed waste.
ENERGY EFFICIENCY AND GREENHOUSE GASES
Qenos operations are large consumers of fuel and electricity. This results in significant carbon
dioxide emissions from both on-site furnace and boiler combustion and off-site electricity
generation.
A number of energy saving steps were identified at Qenos Olefins and implemented in 2003
resulting in savings of about 3000 tonnes. The tonnes CO2 per tonne of production parameter
was 3% lower as shown in Figure 14.
In 2003, Qenos Altona submitted a Greenhouse Management Report to the Victorian EPA as
required by the Greenhouse Gas Emissions and Energy Efficiency in industry PEM. The
report described projects which are scheduled to be completed over the next 4 years which
Annual Report to ACNCG, 2004
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QENOS PTY LTD
are expected to result in savings of 16-17000 tonnes of CO2 per annum. Should the
conversion of SCAL1 to gaseous feed proceed, then additional greenhouse gas abatement
would result.
Figure 14
Tonne CO2/tonne production (includes Resins post
1997)
1.6
1.4
1.2
1
0.8
0.6
0.4
0.2
0
1.4
1.37
1.25
1.07 1.07 1.06
1.14
1.26
1.39
1.23 1.19
1990 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
Note: These figures are taken from the Annual Greenhouse Challenge Update. This CO2
equivalent figure includes carbon dioxide produced by the generation of electricity consumed
by the plants as well as carbon dioxide produced onsite by fuel combustion.
Following international conventions, only CO2 from electricity generation, combustion and
methane is covered.
GROUNDWATER MANAGEMENT PLAN
A round of groundwater monitoring was conducted by Qenos in November to coincide with
monitoring by the other Complex companies. This will assist in determining the effectiveness
of groundwater cleanup activities directed at chlorinated hydrocarbons, being undertaken by
Dow and APPL. The monitoring confirmed that the small benzene plume under the Olefins site
is not changing. Importantly, the offsite monitoring wells, downstream of the plume, continue to
be benzene free.
Another possible source of the plume was eliminated in 2003 when the underground sewers in
the vicinity of the plume were surveyed and found to be intact with no leakage. This was the
last of the possible sources to be eliminated, leaving the most obvious conclusion that the
plume has resulted from some historic source.
Qenos will continue to monitor the plume on an annual basis.
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QENOS PTY LTD
ENVIRONMENT IMPROVEMENT PLAN (EIP)
Qenos’ performance in completing the Action Items in EIP3 is shown below:
Table 3:
Completion of EIP items.
Year
Completed
Deferred Indefinitely
Rolled Over
2001
12
1
9
2002
12
0
2
2003
17
0
3
Total
41
1
14
A total of 17 EIP items were completed or closed out in 2003, including 3 new items that
were added during the year. Good progress was made on a further 3 items that were not
due until end of 2004. 3 items that were due in 2003 have been rolled over for completion
in 2004. These are work on the Olefins Effluent Treatment Plant, diversion of wastes from
landfill and completion of the Groundwater Management Plan. The item deferred indefinitely
is the desludging of the Elastomers cooling pond.
Some of the major achievements included:
•
•
•
•
•
•
•
•
•
•
achieving accreditation of the Resins site and re-accreditation of the other three sites
connection of the Spent Caustic Carbonation system tail gas to the boilers to avoid
generation of highly odorous spent catalyst, and the removal of the spent catalyst
from one of the two reactor beds
a 30% reduction in Butadiene emissions through tightening of LDAR program action
limits
completion of 16 noise reduction projects at Plastics two years ahead of plan
implementation of the WasteCert electronic waste transport certificate system
redirection of Elastomers plant effluent to the Plastics waste water treatment plant
removal of soil stockpiles from Olefins site
installation of new flare tip at Olefins
completion of sewer inspection at Olefins, and development of a routine sewer
inspection plan
completion of the Olefins environmental performance review and progressing the
recommendations from this
Further progress has been made by Collex on the waste to fuel project, with the Works
Approval submitted to the EPA, and briquetting machine selection underway. Qenos is
currently exploring more attractive alternatives for some of the major waste streams that
should result in them becoming saleable products.
Significant reductions in fresh water consumption have been made at the Olefins plant,
which has also resulted in corresponding trade waste volume reductions. Work continues to
further reduce water usage, with options for water re-use being explored.
EIP3 expires in 2004, and work has begun on the development of EIP4.
COMMUNITY RIGHT TO KNOW AND COMMUNITY INTERFACES
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QENOS PTY LTD
Qenos and the Complex continue to be involved in the Altona Complex Neighbourhood
Consultative Group(ACNCG), the City of Hobsons Bay City Pride Committee and Altona
Secondary College Horticultural/City West Water Community Centre through the Complex
Community Liaison Adviser.
The ACNCG consists of senior executive managers from the Altona Chemical Complex
(ACC) together with eleven volunteer representatives nominated from the local community.
Three of these representatives are founding members of the ACNCG, with 15 years of
continuous service each. Other representatives from the Environment Protection Authority
(EPA), WorkSafe Victoria, City West Water (CWW) and City of Hobsons Bay Health
Services department attend the meetings. A Councillor from the Hobsons Bay City chairs
the meetings in an independent capacity. :
This group ensures effective consultation between community and industry providing a
system of accountability and transparency of industry to its local community. e.g. bi-monthly
ACNCG public meetings; alternate monthly site Environment Monitoring Team (EMT)
meetings. EMTs include community representatives); special incident Review teams (called
as required) include community members in all phases of investigation and remediation.
Major sponsorship throughout the year included the Qenos Art Show, funding of the antigraffiti trailer, and financial and goodwill support for Whitelion - an organisation that delivers
a range of programs and services to young people within the juvenile justice system.
Other sponsorships for the year were :
•
•
•
•
•
•
•
•
Ongoing sponsorship Qenos Perpetual `Lynch Shield' - Altona/Altona North District
Cricket Clubs
Altona City Football Club - Junior Development
Kooringal Golf Club - Ladies Bowl
Clean Up Australia Day - Altona
Bayside College - Great Victorian Bike Ride
Rotary Club Charity Golf Day
Altona Softball Club
Various sponsorships to local kindergartens, schools and colleges
Leadership Victoria held a very successful Economics Seminar on our site and participated
in a plant tour.
Qenos continues to attract business and educational/student interest in its operations, and
during the year, hosted a number of tours of its sites.
Whilst there were a number of approaches from students seeking information on plastics,
there were no Community Right to Know enquiries for 2003
PERSONAL SAFETY PERFORMANCE
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QENOS PTY LTD
Qenos aims for worldclass performance in Personal Safety for both its employees and
contractors. Table 4 details the number and type of injuries in 2003 and Figures 14 and 15
detail the long-term trend of our performance in this area. (Total Recordable Injury Rate
(TRIR) is based on the number of reportable injuries per 200,000 hours worked).
Measures put in place in 2002 have resulted in an improvement in the 2003 TRIR and the
introduction of a Behaviour-Based-Safety program on all sites is expected to deliver further
improvement in injury performance in 2004.
The 2003 TRIR for Qenos employees and contractors was 0.6 and 2.5 respectively. Hours
worked were 1.3 million for employees and 250 thousand for contractors.
Table 4 – Personal Safety Performance Figures, Altona 2003
Lost Time Injury
Medical Treatment/Restricted Work Case
Injury
First Aid injuries
Total Recordable Injury Rate (TRIR)
2003
Qenos
Contractor
0
0
4
3
22
0.6
13
2.5
Figure 14
Altona Own Employee TRIR
3.5
3
2.5
TRIR
2
1.5
1
0.5
0
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
Year
The 2003 Qenos contractor performance was disappointing with three reportable injuries
occurring in the 4th quarter. This followed a period of three years in which there were no
reportable injuries on the plants. (The two reportable injuries in 2002 occurred in the
Administration areas).
The three reportable injuries in 2003 occurred while carrying out low-risk activities, (speck of
dust in eye, cut chin on workbench drawer, fractured thumb while handling scaffold poles).
During 2004 continued emphasis will be placed on all contractor activities including the
activities that have traditionally been considered to be low-risk.
Annual Report to ACNCG, 2004
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QENOS PTY LTD
Figure 15
Altona Contractor TRIR
6
5
TRIR
4
TRIR
3
2
1
0
1995
1996
1997
1998
1999
2000
2001
2002
2003
Year
HEALTH INITIATIVES
Workplace exposure monitoring programs for specific chemical and physical agents
continue to be carried out at each of the operating sites. Results indicate that exposures to
these hazards are maintained below occupational exposure standards. Personnel receive
training in the nature, exposure and control of the hazards present in the workplace.
In 2003 the Material Safety Data Sheet system, Infosafe 2000, was used to provide
chemical safety information to all personnel. Hard copy MSDS manuals are available at all
sites for operators and emergency services. MSDSs for all Qenos products are available on
the Qenos website. A major effort was made to ensure all the MSDSs were current.
Qenos maintains management manuals, policies and procedures for hazards encountered
in the workplace. Each site has hazard registers that include asbestos and workplace
hazardous substances.
During 2002 all Qenos industrial cooling tower systems had registrations renewed with the
Department of Human Services (DHS). Legionella risk management plans for the industrial
cooling towers on all sites were internally assessed.
Ongoing medical programs continue to show no evidence of adverse health effects arising
from workplace exposures. The Annual Benzene Medical Surveillance Program, which
focuses on employees potentially exposed to benzene in the workplace, again reported no
health effects that could be related to benzene exposures.
Qenos conducts rigorous internal assessments for compliance with occupational health and
safety legislation.
Continuous improvement projects are initiated as a result of monitoring programs and
internal assessments. These projects are stewarded to completion within specified time
frames. During 2003 Elastomers introduced improved local ventilation to improve control of
hydrocarbons during sampling. Elastomers also demonstrated improved control of
hydrocarbons by introducing new product testing and specifications as well as modifying
plant extraction system operation and maintenance.
Annual Report to ACNCG, 2004
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QENOS PTY LTD
Qenos is striving to minimise employee noise exposure. During 2003 noise control projects
were implemented to reduce employee exposure and plant emissions.
MAJOR HAZARD FACILITIES (MHF) REGULATIONS
All the Qenos manufacturing facilities have been registered as Major Hazard Facilities.
Qenos has a 5 year Licence to Operate, obtained in December 2002 with a condition linked
to Olefins SCAL1 conversion project. Post licensing, WorkSafe implement an ‘Oversight’
activity to ensure licensed facilities safety obligations are met. The scope of WorkSafe
oversight covers major incident safety and all other relevant occupational health & safety
and dangerous goods regulatory obligations.
The oversight activity is managed through a yearly plan established through consultation
with the facility (Qenos) and other government agencies (eg MFESB, Office of Gas Safety
etc). A key activity is a detailed inspection that incorporates a review of safety management
system elements that WorkSafe sees as important for Major Hazard management. In 2003
Qenos had a detailed inspection performed in November, the SMS elements checked were
– Permit to Work, Third Party Management, Management of Change and Asset Integrity.
Additionally a review of WorkSafe nominated safety critical controls was also performed,
this included routine testing and fault management. No major issues were identified. Items
for action are listed in applicable Qenos work lists and will also be followed up in the 2004
oversight plan. A pleasing comment noted in the inspection report from WorkSafe was ‘
fewer issues were raised during this inspection than during the licensing verifications, which
suggests an improvement in the implementation of SHEOS’.
WorkSafe additionally use the number of incidents associated with dangerous goods as a
performance indicator, Qenos and WorkSafe work closely together on the review of these
incidents to determine if there are any issues for follow up.
The 2004 Oversight plan is in the process of being finalised.
Gas Safety (Safety Case) Regulations
Qenos intends to move forward on obtaining a Safety Case for the operation of complex gas
facilities. This includes items such as boilers, furnaces and other gas combustion
equipment.
The Office of Gas Safety (OGS) is the regulator with the responsibility of implementing
these and the associated Gas Installation regulations. Qenos sees this as a means to
enhance the effectiveness of our safety management systems and develop stronger links
with the OGS. It will complement activities linked to the MHF licensing requirements
Electricity Safety Management Scheme (ESMS)
The Electricity Safety Act of 1998 provides the opportunity for individual companies to apply
variations to the regulations to achieve equal or better safety outcomes applicable to
electrical installations through the establishment of an ESMS. The Act also provides the
opportunity for persons authorised under an approved scheme to be exempt from certain
sections of the Act or from the Regulations.
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QENOS PTY LTD
The Office of the Chief Electrical Inspector (OCEI) is responsible for electrical safety in
Victoria and manages the applications received for ESMSs.
Qenos plans to make application for an “employer operator” ESMS to the OCEI in the 4th
quarter of 2004. Final approval may take up to 18 months
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QENOS PTY LTD
DANGEROUS GOODS STORAGE
The following materials classified as Dangerous Goods are stored or processed at Qenos. The
quantity range is shown in tonnes. The data presented below is based on Safety Case
documentation.
Acetylene
Ammonia
Butadiene
Butene/butylene
Carbon Monoxide
Hexane
Ethane
Ethylene
Hydrogen
Hydrogen Sulphide
Nitrous Oxide
LPG
Propylene
Acetone
Benzene
Cyclohexane
Isopropyl Ether
Ethanol
Diesel
Petrol (Motor Spirit)
Heptane
Iso-propanol
Kerosene
Methanol
Pentane
Naphtha (olefins gasoline)
Toluene
Turpentine substitute
Cuprous Ammonia
Acetate
0-1
10-100
1000 - 10000
1000 - 10000
0-1
0-1
0-1
1000 - 10000
1 - 10
0-1
0-1
1 - 10
100 - 1000
0-1
10-100
100 - 1000
1 - 10
0-1
10-100
10-100
0-1
10-100
1 - 10
1 - 10
10-100
1000 - 10000
1 - 10
1000 - 10000
Compressed gas NOS*
0-1
Ethylene
1 - 10
Methane/Natural gas
1 - 10
Propane
10-100
Actrene 230W
1 - 10
Hexene
10-100
DiMethylDisulphide
10-100
Acetic Acid
10-100
Pyrophoric
Organometallic NOS*
10-100
Flammable Liquid NOS*
1 - 10
Bis(Triphenylsilyl)Chromate 0 - 1
Isoprenyl Aluminium
1 - 10
Triethyl Aluminium
1 - 10
Ethyl Aluminium
Sesquichloride
10-100
Diethyl Aluminium Chloride 10-100
Quench Oil
1000 - 10000
Magnesium Ethylate
1 - 10
Diethylaluminium Ethoxide 10-100
Heavy Gas Oil
1000 - 10000
Carbon Black Feedstock 1000 - 10000
Mobil DTE Light
10-100
Diethanolamine
10-100
Ethylene Glycol
1 - 10
Tertiarydodecylmercaptan 1 - 10
Diethylhydroxyamine1 - 10
Organic Peroxide
1 - 10
Butane
0-1
100 - 1000
* NOS denotes “Not Otherwise Specified”
Technical information and Material Safety Data Sheets are available for these materials on
request.
Annual Report to ACNCG, 2004
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QENOS PTY LTD
Annual Report on Manufacturing Operations at Qenos Olefins, Plastics, Resins and Elastomers Sites
to Altona Complex Neighbourhood Consultative Group April 2004
SH&E INCIDENTS:
QENOS PTY. LTD. ALTONA SITES
PROCESS SAFETY
SIGNIFICANT
INCIDENTS
PERSONNEL HEALTH &
SAFETY
Fatality 2
0
0
LTI3
OTHER
INCIDENTS
Table 7:
ENVIRONMENT
1
- Employee
- Contractors
Medical Treatment 4 -Emp
- Cont
First Aid 5
- Emp
- Cont
0
0
4
3
22
13
Leak or spill requiring immediate
MFB and EPA notification 6
A multiple (>=4), accepted
community complaint incident
Leak or spill requiring post-event
notification to relevant authorities6
Accepted community complaint
TRANSPORT
0
3
0
0
0
7
0
41
Incident Summary
1.
Significant Plant Incident: an incident such as a fire, hazardous chemical or flammable dust release or explosion that results in the sounding of the community alarm or accident costs in
excess of $500k
2.
Fatality: a work related death of an employee, on-site contractor or visitor occurring in the period of the survey.
3.
Lost Time Injury/Illness: work related occurrence that results in a permanent disability or time lost from work of one full day or shift or any time after the day of the shift on which the injury
occurred.
4.
Medical Treatment Injury/Illness (not including those involving lost time): a work related injury requiring treatment by a medical practitioner which is beyond the scope of normal firstaid according to the Australian Standard.
5.
First-aid Treatment: a work related one-time treatment and any follow-up visit for observation, of minor scratches, cuts, burns, splinters and the like which do not normally require medical
care. Such treatment is considered to be first-aid even if administered or supervised by a medical practitioner.
6.
Leak and Spill: see “Leak and Spill Reporting Procedures, 1995”
7.
Serious Transport Incident: an occurrence posing a danger or potential danger to life, property or the environment which results from a leakage, spillage, fire or explosion of goods
during transport, including loading and unloading and requiring the presence of emergency services.
8.
Other Transport Incident: an occurrence posing a minor danger to persons, property or the environment which results from a leakage, spillage, fire or explosion of goods during
transport, including loading and unloading.
Annual Report to ACNCG, 2004
Page 27