Coogee Energy Pty Ltd
Methanol Plant
Environment
Improvement
Plan
December 2003
Coogee Energy Pty Ltd
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 2 of 40
Contents
ENDORSEMENT OF THE ENVIRONMENT IMPROVEMENT PLAN 4
1. PREFACE 5
2. COOGEE ENERGY ENVIRONMENTAL POLICY STATEMENT 6
3. SUMMARY OF ENVIRONMENT IMPROVEMENT PLAN OBJECTIVES 7
3.1 Environmental Management 7
3.2 Aesthetic and Ecological Impact of the Facility 7
3.3 Greenhouse Gas and Atmospheric Emissions / Resource Efficiency 7
3.4 Water and Wastewater 8
3.5 Solid and Liquid Wastes 8
3.6 Ground Water 8
3.7 Community Right to Know 8
3.8 Product Stewardship 8
4. COMMUNITY LIAISON COMMITTEE 9
4.1 Mission Statement 9
4.2 Acknowledgments 9
5. METHANOL PLANT OVERVIEW 10
5.1 Background 10
5.2 Site 10
5.3 Production Process 11
5.3.1 Feedstock Preparation 11
5.3.2 Synthesis Gas Generation 11
5.3.3 Methanol Synthesis 11
5.3.4 Distillation, Storage and Distribution 11
5.4 Methanol Properties 12
5.5 Safety 13
6. ELEMENTS OF THE ENVIRONMENT IMPROVEMENT PLAN 14
6.1 Environmental Aspects 14
6.2 Environment Improvement Plan Objectives 14
6.3 Allocation of Priority 15
6.4 Review of EIP Progress Review 15
Coogee Energy Pty. Ltd.
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7. ENVIRONMENTAL ASPECTS AND OBJECTIVES 16
7.1 Environmental Management 16
7.1.1 Regulatory Framework 16
7.1.2 Environmental Management System (EMS) 16
7.1.3 Environmental Audit Program 16
7.1.4 Environmental Training 17
7.1.5 Incident Preparedness and Incident Investigation 17
7.1.6 Risk Assessment 18
7.1.7 Environment Improvement Projects 鈥? Environmental Management 18
7.2 Aesthetic and Ecological Impact of the Facility 19
7.2.1 Overview 19
7.2.2 Process Area and Administration Building 19
7.2.3 Native Grassland Reserve 20
7.2.4 Habitat Hectare Assessment 20
7.2.5 Environment Improvement Projects 鈥? Aesthetic and Ecological Impact of the Facility 21
7.3 Greenhouse Gas and Atmospheric Emissions / Resource Efficiency 21
7.3.1 Overview 21
7.3.2 Atmospheric Emissions from Licensed Discharge Points 22
7.3.3 Flare Tower (F451) 26
7.3.4 Vent Emissions 26
7.3.5 Fugitive Emissions 27
7.3.6 Methanol Plant De-bottlenecking Project 27
7.3.7 Environment Improvement Projects - Greenhouse Gas and Atmospheric Emissions / Resource Efficiency 28
7.4 Noise 28
7.5 Odour 29
7.6 Water and Wastewater 30
7.6.1 Overview 30
7.6.2 Trade Waste 30
7.6.3 Stormwater 31
7.6.4 Past Environmental Performance 32
7.6.5 Environment Improvement Projects 鈥? Water and Wastewater 34
7.7 Solid and Liquid Wastes 34
7.7.1 Environment Improvement Projects - Solid and Liquid Wastes 35
7.8 Ground Water 35
7.8.1 Environment Improvement Projects - Ground Water 36
7.9 Community Right To Know 36
7.9.1 Environment Improvement Projects - Community Right to Know 37
7.10 Product Stewardship 37
7.10.1 Environment Improvement Projects 鈥? Product Stewardship 38
8. GLOSSARY 39
9. REFERENCES 40
Coogee Energy Pty. Ltd.
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 4 of 40
ENDORSEMENT OF THE ENVIRONMENT IMPROVEMENT PLAN
Coogee Energy hereby acknowledges the third Environment Improvement Plan, which has been developed
in consultation with the Community Liaison Committee and in accordance with section 26B of the
Environment Protection Act 1970.
Coogee Energy agrees to abide by this Environment Improvement Plan and to work with the local
community to resolve any environmental issues originating from its facility at Laverton North.
Signed by: 鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??..鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??.
David Dunne, Plant Manager
Coogee Energy Pty Ltd
The following signatories endorse and support this Environment Improvement Plan:
Signed by: 鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??..鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??.
Jim Clements, Manager West Metropolitan Region
Environment Protection Authority Victoria
Signed by: 鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??..鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??.
Keith Green, General Manager Service Sustainability
City West Water
Signed by: 鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??
Peter Gibbs
Wyndham City Council
Signed by: 鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??..鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??.
Valerie Gemmell
Community Representative
Signed by: 鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??..鈥︹?︹?︹?︹?︹?︹?︹?︹?︹?︹?︹??.
Neil Tomlinson
Community Representative
Coogee Energy Pty. Ltd.
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 5 of 40
1. PREFACE
This Environment Improvement Plan (EIP) has been produced by Coogee Energy Pty Ltd in
conjunction with the Community Liaison Committee (CLC).
The Coogee Methanol Plant (CMP), previously known as the Methanol Research Plant (MRP)
was originally owned by BHP Petroleum. Operations were taken over by Coogee Energy, a fully
owned subsidiary of Coogee Chemicals Pty Ltd (WA), in June 2000. In principle, the philosophy
and commitment brought into Coogee Energy remains unchanged from its previous direction and
many of the original environmental objectives have been either retained or improved.
This EIP is a public commitment by Coogee Energy to maintain a high level of environmental
performance. The plan outlines the current status and future improvement plans for various
environmental aspects of the plant operations, which have the potential to cause an environmental
impact. As Coogee Energy is an accredited licensee (licence number EA23356), this EIP also
satisfies the requirement for accredited licensee applicants as specified in section 26B of the
Environment Protection Act 19701.
This EIP is a full revision of the second EIP prepared in August 2000. Details of environmental
aspects and improvement plan objectives are fully outlined in section 7 of this document.
Coogee Energy is responsible for the development and implementation of this EIP. The progress
towards meeting the specific environmental objectives and targets is reviewed by the Community
Liaison Committee on a regular basis.
Figure 1 - Flare and Product Storage Facility
Coogee Energy Pty. Ltd.
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2. COOGEE ENERGY ENVIRONMENTAL POLICY STATEMENT
As an operating division of Coogee Chemicals, Coogee Energy has adopted corporate safety and
environmental policies for the operation of the Methanol Plant.
ENVIRONMENTAL POLICY STATEMENT
General Policy
Coogee Energy is committed to conducting its activities in an environmentally responsible manner.
From a starting point of compliance with all applicable regulations, Coogee Energy will apply a
management system that will ensure the application of the highest practicable environmental
standards to its products, services and processes.
Objectives
To fulfil this policy the company shall:
鈥? include environmental considerations in all planning decisions and its overall corporate strategy.
Products, services and processes shall be properly assessed for potential environmental impact
from the initial design stage through to delivery and disposal;
鈥? develop products and services and operate facilities in such a manner that pollution and waste are
minimised. Consideration will be given to the efficient use of energy and materials, the
sustainable use of renewable resources, and waste recovery and recycling;
鈥? promote its commitment to the environment to its employees, contractors, suppliers, customers
and the community. The company shall be responsive to the concerns of these stakeholders and
incorporate suggested improvements where appropriate;
鈥? aim to continually improve its environmental management system and its environmental
performance taking into account technical developments, scientific understanding, consumer
needs and community expectations. To assist with continual improvement, environmental
performance shall be monitored and a program of internal and external reviews and audits shall
be maintained;
鈥? endeavour to prevent environmental incidents and accidents and have effective contingency plans
available for emergency situations;
鈥? ensure adequate resources and training is provided at all levels and shall ensure there is proper
understanding and implementation of this policy.
Responsibilities
The Managing Director of Coogee Energy has overall responsibility for establishing, implementing
and reviewing the effectiveness of the Coogee Energy environmental policy.
The responsibility for implementing the environmental policy rests with the management team. All
Coogee Energy employees and contractors are required to understand and act in accordance with this
environmental policy.
Coogee Energy Pty. Ltd.
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 7 of 40
3. SUMMARY OF ENVIRONMENT IMPROVEMENT PLAN OBJECTIVES
3.1 Environmental Management (refer to section 7.1)
Issue Improvement Project Outline Target Priority
Completion
Date
Reporting of environmental incidents and
Incident Investigation corrective/preventative actions to the Community Liaison Ongoing High
Committee.
Conduct 2-yearly environmental awareness training for all June 2004 &
Environmental Awareness Training High
personnel. 2006
Implement legal compliance procedure to ensure the plant is
kept up to date regarding environmental legal compliance.
Legal Compliance Ongoing High
Update legal compliance register annually and review at
ESH meeting.
Conduct internal and external environmental audit program
Environmental Audit Program Ongoing High
as discussed in section 7.1.3.
3.2 Aesthetic and Ecological Impact of the Facility (refer to section 7.2)
Issue Improvement Project Outline Target Priority
Completion
Date
Plant additional trees in the front car park area and around First stage
Aesthetics on boundaries of the
the boundary fences, and remove weeds to improve competed 鈥? Medium
Coogee Energy site
aesthetics 鈥? according to staged plan and budgeting. March 2004
Site Pest Control Implement rabbit eradication program. End 2003 Medium
Biodiversity of Native Grassland Investigate grassland management options according to
End 2003 Medium
Reserve / Grassland Management habitat hectare assessment (refer to 7.2.4).
Greenhouse Gas and Atmospheric Emissions / Resource Efficiency (refer to
3.3
section 7.3)
Issue Improvement Project Outline Target Priority
Completion
Date
Review the design of the GHR preheater to improve
Greenhouse gas emissions (CO2 End 2003 High
efficiency and reduce greenhouse emissions.
and NOx) from the GHR preheater
Investigate recovering waste heat from the preheater stack. End 2003 High
Re-investigate increasing the efficiency of the loop
Reduce greenhouse gas emissions
circulators to reduce power requirements and improve End 2003 Medium
(CO2, NOx and CH4) from the loop.
process performance.
Investigate hydrogen recovery for the synthesis gas or loop
Reduce greenhouse gas emissions
purge gas to improve the loop efficiency and reduce the April 2004 Medium
(CO2) from the loop.
amount of purge gas.
Reduce greenhouse gas emissions Annual basis 鈥?
Conduct routine monitoring and maintenance to ensure all
(CO2 and NOx) from the boiler / August 2004, Low
steam traps are working correctly.
steam system. 2005 & 2006
Staged replacement of failed standard fluorescent ferro
Ongoing Medium
magnetic tube ballasts with electronic ballasts.
Reduce greenhouse gas emissions
Continue replacing failed standard fluorescent tubes with
(CO2 and NOx) from building and Ongoing Medium
high density triphosphor tubes.
plant lighting.
Investigate lighting options when new electricity contract
Mid 2005 Low
pricing is known (contract is due for renewal in 2004).
Investigate re-routing flare knock-out drum liquid to crude
Reduce greenhouse gas emissions
methanol tank rather than to fusel oil to increase the process End 2004 Low
(CO2 and NOx) from process.
efficiency of synthesis gas generation section.
Minimise methanol loss from topping Re-evaluate the economic viability of installing a further
column reflux drum by reducing water-cooled heat exchanger in the topping column off-gas Mid 2005 Low
operating temperature stream to recover methanol vapour.
Understanding Greenhouse Investigate greenhouse life cycle analysis of methanol
Mid 2004 Low
Emissions production.
Conduct further investigation into the issues surrounding
Stack Monitoring December 2004 High
sampling point EPA-3 as discussed in section 7.3.2.
Investigate why expected efficiency gains from the new
Maintain plant efficiency End 2004 Low
AGHR internals have not been entirely achieved.
Coogee Energy Pty. Ltd.
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3.4 Water and Wastewater (refer to section 7.6)
Issue Improvement Project Outline Target Priority
Completion
Date
Investigate further methods of reducing cooling tower
Reduction of the volume of
wastewater treatment volumes while still maintaining process Mid 2004 Medium
wastewater
efficiency.
Investigate basing the initiation for the back flush of filters in
Reduction of potable water
the demineralisation plant on pressure drop rather than on a March 2004 Low
consumption.
timer.
Reduction of cooling water used to Investigate the installation of an air cooler to cool boiler
End 2003 Medium
cool boiler blowdown blowdown.
3.5 Solid and Liquid Wastes (refer to section 7.7)
Issue Improvement Project Outline Target Priority
Completion
Date
Investigate ways of reducing packaging materials used for
Ongoing Medium
Waste Reduction goods delivered to site and report to the CLC.
Recycle metal scraps and waste oil. Ongoing High
Recycle unused chemicals from laboratory to other
End 2003 High
organisations.
Send spent catalyst for re-processing to be used as soil
Ongoing High
nutrients.
3.6 Ground Water (refer to section 7.8)
Issue Improvement Project Outline Target Priority
Completion
Date
Ensuring the integrity of the Review installation of a testing hole to enable monitoring for
Mid 2004 Medium
underground laboratory solvent pit leaks from the underground laboratory pit.
3.7 Community Right to Know (refer to section 7.9)
Issue Improvement Project Outline Target Priority
Completion
Date
Continue to provide information to the community as
Ongoing High
Community Right to Know requested.
Quarterly Community Liaison Committee Meetings. Ongoing High
Publish EIP on Coogee Methanol Plant鈥檚 internet site. Mid 2004 Medium
3.8 Product Stewardship (refer to section 7.10)
Issue Improvement Project Outline Target Priority
Completion
Date
Create an information booklet and ensure it is sent to small
End 2003 Low
Product Stewardship customers.
Use recycled drums and encourage drum customers to
June 2004 Low
recycle drums.
Coogee Energy Pty. Ltd.
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4. COMMUNITY LIAISON COMMITTEE
The Community Liaison Committee (CLC) was initially established in 1997 following a public
meeting that was held to attract community members interested in becoming involved in the
environmental management of the Methanol Plant. The CLC seeks to involve the community in
monitoring and improving environmental performance and provides an avenue of communication
between plant management and the community.
Since 1997, over twenty CLC meetings have been held with a range of topics being covered. As
from November 2002, Coogee Energy combined resources with Orica Chloralkali to hold joint
CLC meetings in an effort to increase community interest and prevent numbers of attendees from
diminishing. The current members of the joint CLC are:
Community Representatives: Andrew Clifton
Valerie Gemmell
Neil Tomlinson
EPA Representative: Doug Buchanan
City West Water Representative: Joe Messina
Wyndham City Council: Peter Gibbs
Coogee Energy Representatives: David Dunne (Plant Manager)
Tauna Morihovitis (Process Engineer)
Orica Chloralkali Representative: Stuart Newman (Manufacturing Manager)
4.1 Mission Statement
The Community Liaison Committee developed the following mission statement for the Methanol
Plant to focus the objectives of the committee:
MISSION STATEMENT
鈥? To monitor and improve the environmental performance of the Methanol Plant.
鈥? To establish effective methods of communication between the management of the
Methanol Plant and the community.
鈥? To demonstrate the value of community involvement in environmental management.
4.2 Acknowledgments
Coogee Energy would like to thank the members of the Community Liaison Committee for their
contribution, and the enthusiasm they have demonstrated during the development of the
Environment Improvement Plan. The contribution of all involved will have a direct effect on the
improved environmental outcomes which will benefit the community as a whole.
Coogee Energy Pty. Ltd.
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5. METHANOL PLANT OVERVIEW
5.1 Background
Coogee Energy Pty Ltd purchased the majority ownership of the Methanol Plant from BHP
Petroleum in June 2000. Coogee Energy is a wholly owned subsidiary of Coogee Chemicals Pty
Ltd, a chemical manufacturing company based in Western Australia. Together with its joint
venture partner, Mogal Marine, Coogee Energy has ownership of the Methanol Plant as well as
the technology rights for offshore methanol production.
The Coogee Methanol Plant is Australia鈥檚 only methanol production facility, and is currently
capable of producing between 70,000 to 80,000 tonnes per annum of chemical grade methanol.
The plant operates 24 hours a day, 7 days a week, all year round with the exception of scheduled
shutdowns which take place approximately every year or as required for maintenance and catalyst
change outs.
In Australia, the methanol is primarily used as a chemical intermediate for the manufacture of
resin for the timber products industry. Ultimately the methanol ends up (as resins) in products
such as plywood, particle board or fibre board, which are used either in the domestic building
industry or exported to Asian markets.
Historically, the Methanol Plant was built to demonstrate offshore methanol production
technology. Australia has significant oil and natural gas resources that are situated in remote and
offshore locations in Northern and Western Australia. Due to the size and location of these oil and
gas reserves it is not economical to bring the gas to shore to use it as fuel or for manufacturing. To
avoid burning the gas off, a new, but untried methanol production technology was licensed from
the UK in order to develop the technology on land prior to the development of an offshore plant.
The Leading Concept Methanol process in use at the Methanol Plant has various advantages
compared with conventional methanol production processes. Some of those advantages are that it
is efficient and compact, it substantially reduces waste through the internal recycling of process
effluents, and it produces the least greenhouse gas emissions of any methanol production
technology.
Construction of the Methanol Plant commenced in 1993, with the start up of the plant occurring
on 17th October 1994. An extensive research and development program was, and still is being
undertaken, with the information being used to conceptually develop the offshore methanol
production facility. The development of this technology at the Laverton facility will ultimately
prevent significant quantities of natural gas having to be flared while oil is being recovered from
offshore oil fields.
5.2 Site
The Methanol Plant was located at the William Angliss Industrial Estate in Laverton North
because of both the convenient supply of Bass Strait natural gas and the close proximity to two
major consumers of methanol (Orica Adhesives, Deer Park and Borden Australia, Laverton).
The total area of the site is approximately 8 hectares, of which approximately half is currently
occupied by plant, buildings and product handling facilities, and approximately 3.5 hectares at the
western end of the site is set aside as a native grassland reserve. The planning zone of the
premises is Industrial 2 Zone (IN2Z), with the closest residential area being located 2.7 kilometres
away. The Methanol Plant鈥檚 industrial neighbours are Qenos Plastics to the south and Kalari
Transport Services to the north.
Coogee Energy Pty. Ltd.
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5.3 Production Process
5.3.1 Feedstock Preparation
The main raw materials used in the production of methanol are natural gas and oxygen. Natural
gas feedstock is delivered to the plant via a spur pipeline from the main Melbourne to Geelong
trunkline. The gas is first compressed and then purified by removing sulfur compounds.
5.3.2 Synthesis Gas Generation
The purified natural gas is then saturated with heated and recycled process water. The mixed
natural gas and water vapour then goes to the advanced gas heated reformer (AGHR) to be
partially converted to a mixture of carbon monoxide (CO), carbon dioxide (CO2), methane (CH4)
and hydrogen (H2). This partially converted gas is then completely converted to synthesis gas
(CO, CO2 and H2) by reaction with oxygen in the secondary reformer.
5.3.3 Methanol Synthesis
The synthesis gas is then converted to crude methanol in a catalytic synthesis converter. The crude
methanol contains approximately 82 % methanol and 18 % water plus some organic impurities.
5.3.4 Distillation, Storage and Distribution
The crude methanol is purified to standard quality specifications by removing water and organic
impurities through distillation. The organic impurities and water are recycled within the process.
The Methanol Plant can currently produce approximately 70,000 鈥? 80,000 tonnes of methanol per
year. The refined methanol is stored in storage tanks on site. The methanol is supplied by
underground pipeline to Orica Adhesives in Deer Park and Borden Australia in Laverton.
Methanol is also transported via road tanker to a resin manufacturer, Woodchem Australia, located
in Oberon NSW and to various smaller consumers of methanol. Coogee also leases a 2,400 tonne
storage tank at the Vopak terminal in Botany, which is used either for additional storage or
import/export. Methanol is transported to or from this tank via road tanker.
In 2002, Coogee Energy began selling drums of methanol primarily to the racing fuel market as it
is both a safer fuel and has a higher octane rating than petrol. Coogee Energy also sells smaller
amounts of drummed methanol into the biodiesel and chemical industries. Methanol is transported
via road tanker to an external facility, which looks after the drumming, storage and distribution of
drums.
Coogee Energy Pty. Ltd.
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Figure 2 - Methanol Production Process Overview
5.4 Methanol Properties
Methanol (CH3OH), also called methyl alcohol, is a clear, colourless, flammable liquid. Methanol
is flammable in air in concentrations between 6 % and 36 %. The following information is
provided from the material safety data sheet (MSDS) for methanol.
UN Number: 1230
CAS No: 67-56-1
HAZCHEM: 2WE
Dangerous Goods Class: 3 (Flammable liquid)
Dangerous Goods Sub. Risk: 6.1 (Toxic substance)
Packing Group: II
Poisons Schedule: S6
Boiling Point: 65掳C
Flash Point: 12掳C
Coogee Energy Pty. Ltd.
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5.5 Safety
The Methanol Plant includes safety features typically used in modern petrochemical plants. A
range of instrumentation with alarms, trips and interlocks is used to minimise the occurrence of
hazardous incidents or warn of their possibility. Plant equipment is protected from overpressure
by pressure safety valves which relieve to a clean burning smokeless flare stack.
In the event of a gas leak, the facility has installed flammable and toxic gas detectors to provide
early warning so that the plant can be safely shut down. Additionally, equipment is routinely
monitored and checked to detect minor leaks through both a comprehensive leak detection
program which is carried out 6-monthly (refer to section 7.3.5 for further detail), and during
routine plant checks which are carried out once per shift by a field technician.
Produced methanol is stored in two 2,000 tonne tanks which have fixed external roofs and floating
internal roofs with nitrogen above them to act as an inert buffer, providing additional safety. This
design minimises any risks of fire in the tanks and also minimises fugitive vapour emissions.
The plant is equipped with an integrated firefighting system including firewater pumps, deluge
systems and fire detection equipment.
Coogee Energy has an integrated Management System which includes a comprehensive Safety
Management System (SMS). This system provides best practice procedures for maintaining the
highest standard of safety, health and environmental performance. The system has been designed
to meet and integrate the requirements of the following compliance standards:
鈥? ISO 9001:2000 鈥? Quality Management Systems2
鈥? ISO 14001:1996 鈥? Environmental Management Systems3
鈥? NOHSC:1014 (1996) 鈥? National Standard for the Control of Major Hazard Facilities4
鈥? PACIA (Plastics and Chemical Industries Association) Responsible Care Program
All employees are regularly trained in relevant aspects of the SMS.
Coogee Energy Pty. Ltd.
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6. ELEMENTS OF THE ENVIRONMENT IMPROVEMENT PLAN
6.1 Environmental Aspects
An environmental aspect is defined as an element of an organisation鈥檚 activities, products or
services that can interact with the environment3. The environmental aspects relevant to the
Methanol Plant were determined in consultation with the CLC during the development of Coogee
Energy鈥檚 first EIP. The environmental aspects identified for inclusion in the EIP were those seen
to have the potential to cause significant environmental impact.
During the EIP revision process, the environmental aspects were reviewed by the EIP review team
(consisting of Coogee Energy management and CLC representatives). A few changes were made
to produce Coogee Energy鈥檚 current list of environmental aspects:
鈥? Environmental Management
鈥? Aesthetic and Ecological Impact of the Facility
鈥? Greenhouse Gas and Atmospheric Emissions / Resource Efficiency
鈥? Noise
鈥? Odour
鈥? Wastewater
鈥? Solid and Liquid Wastes
鈥? Ground Water
鈥? Community Right to Know
鈥? Product Stewardship
These aspects are discussed in more detail in section 7. Background information and historical
environmental performance data (where applicable) is presented with each topic. A table is
presented for most aspects, summarising their potential environmental impact as explained below:
Table 1 鈥? Explanation of Aspect and Impact Table
Refers to the activity that has a potential impact
Activity or Environmental Aspect
upon the environment. (eg: flaring)
Refers to the element of the natural environment
Environmental Element Affected
that is affected by the activity (eg: Atmosphere)
Describes the potential effect upon the natural
Potential Environmental Effect or Impact
environment that is a result of the activity being
conducted. These may be perceived effects and
do not necessarily represent the status at the
Methanol Plant (eg: emissions of greenhouse
gases)
Refers to the extent of the impact (eg: local /
Extent
regional / global )
6.2 Environment Improvement Plan Objectives
Environment improvement plan objectives were established for the areas where Coogee Energy
seeks to improve its environmental performance. Coogee Energy developed this list of objectives
by reviewing the status of all improvement projects from the last EIP and identifying any ongoing
or uncompleted items to be carried forward, as well as some potential new items to be included in
this EIP. This list was discussed with the EIP review team to give CLC representatives an
opportunity to offer input. After considering their suggestions, the final list of EIP projects was
produced.
Coogee Energy Pty. Ltd.
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Each improvement project is allocated a target completion date and a priority. The level of priority
was assigned according to the matrix explained below in section 6.3.
The ultimate responsibility for implementing the improvement projects remains with the
management of the Methanol Plant.
The environment improvement plan objectives for each environmental aspect are documented in
section 7.
6.3 Allocation of Priority
The level of priority of the environment improvement projects was assigned considering the net
benefit of implementation (taking into account both environmental and cost benefits) and the ease
of implementation. Any EIP objectives which involved legislative requirements or management
commitments were automatically assigned as high priority. All other improvement projects were
assessed using the prioritisation matrix as shown below.
鈫? HIGH MEDIUM HIGH HIGH
Ease of
MEDIUM
Implementation LOW MEDIUM HIGH
鈫? LOW LOW LOW MEDIUM
LOW MEDIUM HIGH
鈫? 鈫?
Net Benefit of Implementation
Priorities:
HIGH 鈥? Allocate resources to implement as soon as possible.
MEDIUM 鈥? Allocate resources when available to implement.
LOW 鈥? Allocate resources only when other priorities are complete.
6.4 Review of EIP Progress Review
The progress towards meeting the EIP objectives and targets is reviewed by Coogee Energy at the
5-weekly ESH meetings. EIP progress is also reported to and discussed with the Community
Liaison Committee on a regular basis.
An environmental performance report, which is submitted to the EPA annually as a requirement of
Coogee Energy鈥檚 accredited licence, outlines Coogee Energy鈥檚 overall environmental
performance and progress on implementing the improvement projects in the EIP.
A full revision of the EIP is conducted every three years.
Coogee Energy Pty. Ltd.
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 16 of 40
7. ENVIRONMENTAL ASPECTS AND OBJECTIVES
7.1 Environmental Management
7.1.1 Regulatory Framework
All acts, regulations, licences and permits relevant to the Methanol Plant are identified in Coogee
Energy鈥檚 Legal Compliance Register. A procedure is in place to ensure that the Legal Compliance
Register is maintained and updated periodically. The licences and permits under which Coogee
Energy operates include:
鈥? EPA Accredited Licence EA233565
鈥? City West Water Trade Waste Agreement (Trade Waste No. 40202073)
鈥? National Industrial Chemicals Notification and Assessment Scheme (NICNAS)
鈥? Licence to Manufacture and Sell or Supply by Wholesale Poisons or Controlled Substances
(other than Schedule 8 or Schedule 9 Poisons)
7.1.2 Environmental Management System (EMS)
A comprehensive Environmental Management System (EMS) has been developed for the ongoing
operation of the Coogee Methanol Plant. The EMS includes detailed policies and procedures to
ensure sound environmental practices are maintained to a high standard.
The EMS is a part of an integrated management system based on the quality management
principles of ISO 90012 and which incorporates the guiding principles outlined in ISO 140013.
The EMS was originally evaluated and benchmarked against the Australian Standard AS/NZS
ISO 14001:1996 by an EPA appointed Environmental Auditor for Industrial Facilities, Peter J
Ramsay & Associates, in 1997. Assessment of the EMS included interviews with plant personnel
to ensure the EMS was fully implemented. The auditor certified that 鈥渢he MRP had a suitable
EMS in place which was capable of achieving the grounds for granting an accredited licence
under Section 26B(2) of the Environment Protection Act 1970.鈥?
The EMS has been reviewed and updated since its original development and has been subjected to
both regular corporate environmental systems audits conducted by both BHP Petroleum (Victoria)
and more recently, Coogee Chemicals (WA), and external audits conducted by an EPA appointed
environmental auditor. In all cases, the audits concluded that Coogee Energy鈥檚 EMS is of a high
standard and complies with the conditions of the EPA accredited licence.
7.1.3 Environmental Audit Program
Coogee Energy has an environmental audit program in place to review the performance of the
EMS and ensure that the requirements of the EPA accredited licence are met. These audits are
arranged in accordance with the CMP Audit Schedule, which is a controlled document in Coogee
Energy鈥檚 Management System.
Coogee Energy鈥檚 environmental audit program consists of the following:
- An external environmental audit conducted by an EPA appointed auditor every two years and
an external Coogee Chemicals corporate environmental audit every alternate year.
- Internal audits, which are conducted three-monthly.
Coogee Energy Pty. Ltd.
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External audit scope
The scope of external audits is to review all of the following five key aspects:
- Environmental Management System
- Compliance (with Accredited Licence performance requirements)
- Waste
- Risk
- Environmental Impact
Internal audit scope
The three-monthly internal audits each focus on a certain section of the EMS. The area to be
audited is usually selected according to any issues that may need to be addressed at the time. This
ultimately results in all aspects of the EMS eventually being audited.
Coogee Energy is committed to maintaining the ongoing environmental audit program. As part of
this commitment, further external audits will be planned according to the CMP Audit Schedule as
follows:
鈥? March 2004 鈥? External Environmental Audit conducted by an EPA Appointed Auditor
鈥? March 2005 鈥? External Corporate Environmental Audit
7.1.4 Environmental Training
Environmental Awareness Training is conducted for all Coogee Energy personnel on an ongoing
basis and at a minimum of every 2 years. The program examines general environmental issues
such as the greenhouse effect and waste minimisation principles. Specific environmental
management practices relating to the operation of the plant are also discussed. The training takes
the approach that all employees at the plant are responsible for environmental performance in their
workplace.
A Competency Based Training and Assessment (CBTA) program is used to ensure Production
Technicians are skilled in the operations they perform. This training is carried out as required
depending upon the previous experience and training of the employee and as assessed by their
manager.
7.1.5 Incident Preparedness and Incident Investigation
An Emergency Response Plan (ERP) has been developed for the Methanol Plant. This plan
documents the roles and responsibilities of plant personnel in the case of an emergency, and
includes general procedures for realistic emergency events. All personnel are trained in the ERP
as a part of their initial induction. A review of the ERP, including discussion of emergency
scenarios is conducted with all personnel on an annual basis. Regular tabletop exercises, which
include topics on emergency preparedness and response, are run by support staff and discussed
with each shift. Simulated emergency response exercises, which involve emergency services, are
carried out periodically to test emergency preparedness and the effectiveness of the ERP.
Information gained from these exercises is used to improve the emergency response capabilities of
all personnel likely to attend the plant in the event of a real emergency.
Safety and environmental incidents are formally reported within Coogee Energy as per the
comprehensive Incident Notification and Investigation system which is documented within the
Management System. The system is used for the reporting of all incidents and near misses and
covers the full investigation of incidents, determination of root causes and identification of
corrective/preventative actions.
Coogee Energy Pty. Ltd.
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 18 of 40
A database of all incidents is maintained and outstanding actions are reviewed at the 5-weekly
ESH meetings. Incidents are also discussed with the Community Liaison Committee.
In the case of an environmental incident involving any abnormal discharge of material outside
licence conditions, Coogee Energy notifies the EPA within 24 hours. A copy of the Incident
Investigation Report is then forwarded to the EPA on completion. Records of these events are
documented and maintained as well as being reported to the Community Liaison Committee for
review and discussion.
7.1.6 Risk Assessment
Risk and hazard assessments were performed on the plant during the design phase and repeated
after the construction and commissioning of the plant.
In 1996 the National Standard for the Control of Major Hazard Facilities, NOHSC:1014 (1996)4
was issued. This standard was updated in 20026. The Coogee Methanol Plant does not meet the
threshold requirements for classification as a major hazard facility as defined by this standard.
Nevertheless, a Formal Safety Assessment (FSA), which is a part of the plant鈥檚 Safety Case was
conducted in mid-1997. The assessment examined the likelihood and impact of potential major
accident events and the means to prevent or minimise their occurrence or consequences to as low
as reasonably practicable. The hazard register documents the following information for each of the
hazards identified at the Methanol Plant:
鈥? Description of the event
鈥? Cause(s) of the event
鈥? Consequences of the event
鈥? Preventative and mitigating actions
鈥? Safety management system interactions.
In addition to the Formal Safety Assessment, the following systems are in place to minimise risk
during the day to day operation of the Methanol Plant by identifying hazards and assessing the
associated risks (including risk to the environment):
- Permit to work system
- Plant modification system
- Job safety analysis undertaken for hazardous jobs
- Annual major hazard review
- HAZOP conducted every 5 years
7.1.7 Environment Improvement Projects 鈥? Environmental Management
Issue Improvement Project Outline Target Priority
Completion
Date
Reporting of environmental incidents and
Incident Investigation corrective/preventative actions to the Community Liaison Ongoing High
Committee.
Conduct 2-yearly environmental awareness training for all June 2004 &
Environmental Awareness Training High
personnel. 2006
Implement legal compliance procedure to ensure the plant is
kept up to date regarding environmental legal compliance.
Legal Compliance Ongoing High
Update legal compliance register annually and review at
ESH meeting.
Conduct internal and external environmental audit program
Environmental Audit Program Ongoing High
as discussed in section 7.1.3.
Coogee Energy Pty. Ltd.
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7.2 Aesthetic and Ecological Impact of the Facility
7.2.1 Overview
The aesthetic and ecological impact of the facility examines environmental issues associated with
the Methanol Plant being located in Laverton North. Issues such as the effects on local flora and
fauna, and the aesthetics of the plant were assessed as part of the original EIP. Table 2 details the
environmental aspect of the facility impact.
Table 2 鈥? Aspect and Impact Table for the Aesthetic and Ecological Impact of the Facility
Aesthetic and Ecological Impact of the Facility
Activity or Environmental Aspect
Local community
Environmental Element Affected
Flora (Native grasslands)
Fauna (Birds, reptiles, mammals)
Aesthetics of local area
Potential Environmental Effect or Concern
Native grassland viability
(Local / Regional) / (National / Global)
Extent
7.2.2 Process Area and Administration Building
The Coogee Methanol Plant site is maintained in a clean state through regular inspections and
maintenance programs.
Landscaping at and around the Coogee Methanol Plant contains a variety of indigenous species.
The use of indigenous species reduces watering requirements, as they are adapted to the heavy
clay soils and dry summer conditions.
Figure 3 鈥? Coogee Energy Administration Building photograph, August 2000.
Coogee Energy Pty. Ltd.
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 20 of 40
7.2.3 Native Grassland Reserve
As the first commercial development of the William Angliss estate in 1992, BHP Petroleum
agreed to purchase the Methanol Plant site under a Section 173 (of the Planning and Environment
Act 1987) obligation. This committed approximately 3.5 hectares at the western end of the site to
be left undeveloped as a native grassland reserve. Coogee Energy is now responsible for the
management of this reserve.
The reserve was primarily designed as a protected habitat for the rare spiny rice flower, Pimelea
spinescens and striped legless lizard, Delma impar. The most widespread vegetation community
in the grassland reserve is Kangaroo Grass, Themeda triandra, but various other indigenous
species of flora are also present.
Management and behaviour of the grassland reserve was the subject of studies being conducted by
the Victoria University of Technology (VUT), Department of Environmental Management.
These studies took place over four years and concluded in late 1999. From discussion with VUT
following completion of this study, it appears that the Coogee grassland reserve shows no major
differentiating features compared with other substantially larger grassland sites located in this
region. This is a very pleasing result, as it shows that the grassland reserve is not unique in this
area. The VUT is therefore concentrating more of their effort into a much larger grassland reserve,
which has more environmental significance.
The relatively small native grassland reserve on the Coogee Energy site is now almost completely
surrounded by other commercial facilities. Despite carrying out a number of weed control
programs, weed species are increasing due to factors such as the grassland鈥檚 large perimeter in
relation to its size and the proximity to adjoining grazed and weed dominated land to the north and
south. It appears that the striped legless lizard, Delma impar, is only present in very small
numbers (if present at all). If the reserve is left in its natural state, it is also a source of
combustible material, which presents a significant hazard to Coogee Energy鈥檚 operations and to
surrounding businesses. Providing a means of fire prevention (i.e. fire breaks) will further devalue
the grassland.
Coogee Energy鈥檚 current view is that there may be more environmentally beneficial ways of
committing the funds set aside for the management of the native grassland while still achieving
our initial environmental objectives. This is being explored with all relevant stakeholders.
7.2.4 Habitat Hectare Assessment
Coogee Energy is reviewing a range of grassland options with a consultant (Environmental
Resources Management), together with other organisations and stakeholders to establish ways to
best utilise the current resources and funding. However, this approach requires careful
consideration and consultation to ensure an outcome that will provide the greatest environmental
benefit.
A Habitat Hectare assessment of Coogee Energy鈥檚 grassland was conducted in February 2003.
This method is used to assess vegetation quality based on comparisons between existing
vegetation features and those of 鈥榖enchmarks鈥? representing the average characteristics of native
vegetation of the same community type in a natural or undisturbed condition. The benchmark
condition score is one. The recent assessment indicated that the habitat score of the Coogee
grassland was 0.43. This translates to a Habitat Hectare Value of:
3.5 ha (area of grassland) 脳 0.43 (habitat score) = 1.51 Habitat Hectares
Coogee Energy Pty. Ltd.
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Coogee Energy is reviewing a number of grassland management options which would provide the
required offset for this Habitat Hectare value.
7.2.5 Environment Improvement Projects 鈥? Aesthetic and Ecological Impact of the Facility
Issue Improvement Project Outline Target Priority
Completion
Date
Plant additional trees in the front car park area and around First stage
Aesthetics on boundaries of the
the boundary fences, and remove weeds to improve competed 鈥? Medium
Coogee Energy site
aesthetics 鈥? according to staged plan and budgeting. March 2004
Site Pest Control Implement rabbit eradication program. End 2003 Medium
Biodiversity of Native Grassland Investigate grassland management options according to
End 2003 Medium
Reserve / Grassland Management habitat hectare assessment (refer to 7.2.4).
7.3 Greenhouse Gas and Atmospheric Emissions / Resource Efficiency
7.3.1 Overview
On a global basis, greenhouse gases (GHGs) such as carbon dioxide and methane are considered
to be the most significant atmospheric emissions. The build up of these GHGs in the atmosphere
through human activity is thought to potentially cause climate change worldwide. Although there
are still uncertainties about the effects of climate change, industry has an obligation to address the
greenhouse issue by reducing GHG emissions and improving energy efficiency.
Greenhouse gas and atmospheric emissions from the Methanol Plant include carbon dioxide
(CO2), carbon monoxide (CO), methanol vapour (CH3OH), water vapour, nitrous oxides (NOx)
and volatile organic carbon compounds (VOCs). The Methanol Plant鈥檚 principal source of GHG
emissions is carbon dioxide.
Unfortunately, during 2001 and 2002 the plant experienced technical problems that negatively
impacted on plant efficiency. Consequently, despite the implementation of action items during
2002 which contributed to CO2-e savings, there was a slight overall increase in emissions from the
previous reported year (2000 calendar year) as seen in the table below.
Table 3 鈥? Tonnes of carbon dioxide equivalent per tonne of methanol produced. Note that the
methodology used for emission measurement was changed in 2002.
2000 2002
Tonnes CO2-e per tonne of
0.762 0.781
methanol produced
Activities related to energy generation are directly responsible for emissions of GHGs. To reduce
GHG emissions from the plant, Coogee Energy monitors the energy efficiency of the operation on
a daily basis. Reactant gases are recycled within the process, and purge streams from the
reforming, methanol synthesis and distillation sections of the plant are burnt in the preheater or
boiler to recover the available energy. Coogee Energy works to improve plant performance via
ongoing technology development and through a continual focus on plant efficiency and process
improvements.
Coogee Energy Pty. Ltd.
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The Coogee Methanol Plant comprises novel technology designed to maximise plant efficiency.
However, the process is heavily heat integrated making it difficult to achieve significant
reductions in emissions, as an improvement in one part of the process can often result in an
inefficiency in another part of the process. Nonetheless, Coogee Energy remains committed to
reducing greenhouse gas emissions and continues to seek opportunities for further greenhouse gas
reductions.
Coogee Energy demonstrated its commitment to reducing greenhouse gas emissions by becoming
a voluntary member of the Commonwealth Greenhouse Challenge in December 2001. As part of
the Greenhouse Challenge, Coogee Energy undertook an energy audit during 2001 in order to
identify areas of inefficient energy use and establish cost-effective actions to increase energy
efficiency, and consequently reduce greenhouse gas emissions. This energy audit also satisfied
requirements of the State Environment Protection Policy (Air Quality Management) that was
gazetted in December 2001.
Outstanding actions remaining from the energy audit have been included in this revision of the
EIP. Additional actions have also been identified by Coogee Energy for inclusion in this EIP.
Further projects to reduce greenhouse gas emissions and improve resource efficiency have been
identified as part of a plant de-bottlenecking project which is detailed in section 7.3.6. Over the
coming year, Coogee Energy is looking to increase production rate while maintaining or
improving efficiency. Coogee Energy鈥檚 aim is to achieve a decrease in the tonnes of CO2-e
emitted per tonne of methanol produced. However, substantial investment would potentially be
required to achieve this aim, so the implementation of projects would be subject to cost benefit
analysis.
Table 4 details the environmental aspect of greenhouse gas and atmospheric emissions / resource
efficiency.
Table 4 鈥? Aspect and Impact Table for Greenhouse Gas and Atmospheric Emissions / Resource
Efficiency
Greenhouse Gas and Atmospheric Emissions /
Activity or Environmental Aspect
Resource Efficiency
Atmosphere
Environmental Element Affected
鈥? Emissions of CO2 and CO in unburnt gas
Potential Environmental Effect or Concern
鈥? Emissions of methanol vapour
鈥? Contribution to the Greenhouse effect
鈥? Potential for inefficient energy/resource use
鈥? Increased pollution
Global / Regional / Local
Extent
7.3.2 Atmospheric Emissions from Licensed Discharge Points
Currently, there are three atmospheric discharge points licensed with the EPA Victoria
(Accredited Licence Number: EA23356)5. The remaining discharge points, while not licensed
must comply with the State Environment Protection Policy (Air Quality Management).7
Coogee Energy Pty. Ltd.
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Flare
Methanol
Storage
Tanks
Tanker
Preheater
Loadout
EPA-1
Vent
Treatment Pits
EPA-3
Cooling Tower
Package
Boiler
EPA-2
Figure 4 - Emission points from the Methanol Plant. Water vapour is emitted from the cooling
tower.
The three licensed atmospheric discharge points (see Figure 4), which are monitored on an annual
basis are:
鈥? Discharge Point 1 (EPA-1) 鈥? GHR preheater (F362) stack
鈥? Discharge Point 2 (EPA-2) 鈥? Package boiler (F361) stack
鈥? Discharge Point 3 (EPA-3) 鈥? Saturator Discharge Separator
The emissions from EPA-1 and EPA-2 are combustion gases such as carbon dioxide (CO2) and
carbon monoxide (CO). The efficiency of the GHR preheater and package boiler are continuously
monitored using oxygen probes to ensure complete combustion of the fuel and to maximise the
energy efficiency. The expected emissions from EPA-3 are water vapour and methanol vapour.
Coogee Energy Pty. Ltd.
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Figure 5 - Stack gas sampling on the boiler stack (EPA-2). The GHR Preheater Stack is to the
right of the boiler stack. Note that there are no visible emissions from these stacks.
All stack gas monitoring is performed by consultants accredited with the National Association of
Testing Authorities, Australia (NATA). The company that carried out this monitoring from 1995
through to 2001 was Amdel. However, during an audit in 2001, it was discovered that the results
from the VOC testing method used by Amdel did not include methane and its derivatives. It is
quite probable that the VOC limit originally specified for EPA-3 was not to include emissions of
methane. This was overlooked at the time Coogee Energy鈥檚 accredited licence was prepared.
Following this finding, another company, EML Air, was engaged to carry out the annual gas
monitoring from March 2002 onwards. Since then, results obtained have showed that EPA-1 and
EPA-2 emissions continue to remain well with the licence limits. However, the EPA-3 VOC
results of 620 g/min (March 2002), 320 g/min (April 2002) and 260 g/min (January 2003) have all
exceeded the licence limit of 18 g/min. In January 2003, a VOC speciation showed that the VOCs
being discharged from EPA-3 consisted primarily of methane. During the January 2003 testing of
EPA-3, the presence of carbon monoxide was also unexpectedly detected.
A thorough investigation into the EPA-3 VOC emission results was conducted. The saturator
discharge separator, SP-1207, is a flash vessel with the majority of the flash stream being water
vapour that needs to be removed from the sample prior to the sample being run through a gas
chromatograph. The difficulty of sampling under these saturated conditions causes inaccuracy in
the measured results. Results from modelling the saturator circuit using various process conditions
showed that in theory, the VOC results should be significantly lower than those we have been
obtaining in practice.
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The EPA would like Coogee Energy to conduct further investigation into sampling point EPA-3,
in order to gain a better understanding of the results that are being observed. Coogee Energy
commits to carrying out this investigation, as formalised in this EIP.
Historical discharges for EPA-1, EPA-2 and EPA-3 for the period from 1995 to present are shown
in Figures 13 to 15.
EPA Discharge Point 1 - GHR Preheater Stack
7.0
6.0
Total Mass Rate, g/min
5.0
NOx
4.0
CO
3.0 VOC
2.0
1.0
0.0
Jan-95
Jul-95
Nov-95
Jun-96
Jan-97
Jul-97
Jan-98
Feb-99
Mar-00
Mar-02
Jan-03
Jun-03
Apr-01
Apr-02
Figure 6 鈥? Stack Monitoring EPA Discharge Point 1 - GHR Pre-heater Stack (Note: In June
2003, VOC results are not graphed because speciated VOCs were measured instead
of total VOCs)
EPA Discharge Point 2 - Boiler Stack
16
14
Total Mass Rate, g/min
12
10
NOx
8 CO
VOC
6
4
2
0
Jan-95
Jul-95
Nov-95
Jun-96
Jan-97
Jul-97
Jan-98
Feb-99
Mar-00
Mar-02
Jan-03
Jun-03
Apr-01
Apr-02
Figure 7 鈥? Stack Monitoring EPA Discharge Point 2 - Package Boiler Stack (Note: In June
2003, VOC results are not graphed because speciated VOCs were measured instead
of total VOCs)
Coogee Energy Pty. Ltd.
Coogee Energy Pty. Ltd. - Methanol Plant - Environment Improvement Plan EIP 2003 | Revision: 3 | Page 26 of 40
EPA Discharge Point 3 - Saturator Discharge Separator
620 320 260
9.0
8.0
7.0
Total Mass Rate, g/min
6.0
5.0 VOC
CO
4.0
3.0
2.0
1.0
0.0
Jan-95
Jul-95
Nov-95
Jun-96
Jan-97
Jul-97
Jan-98
Feb-99
Mar-00
Mar-02
Jan-03
Jun-03
Apr-01
Apr-02
Figure 8 鈥? Stack Monitoring EPA Discharge Point 3 鈥? Saturator Discharge Separator (Note:
testing for carbon monoxide at EPA-3 is not a requirement of Coogee Energy鈥檚 licence 鈥?
carbon monoxide was first sampled in Jan 2003 and unexpectedly detected as discussed
above).
7.3.3 Flare Tower (F451)
A flare tower operates continually and ensures complete combustion of purge gases from the
plant. The flare tower is a safety feature of the plant and allows for safe depressurisation of the
plant in the case of a plant shutdown. The flare is designed to produce no smoke. The flow rate
from the flare is monitored on a continuous basis.
7.3.4 Vent Emissions
Vent emissions must comply with the State Environment Protection Policy (Air Quality
Management)7.
Methanol is a Class 2 indicator. Class 2 indicators are defined hazardous substances that may
threaten the beneficial uses of the air environment by virtue of their toxicity, bio-accumulation or
odorous characteristics. In the case of methanol, the primary reason for its classification as a Class
2 indicator is its odour. The limit for methanol, as specified in the SEPP (AQM) is 5.5 mg/m3 or
4.3 ppm.
As part of an environment improvement and waste minimisation program, a 鈥渟crubber鈥? system
was installed and commissioned in May 1998 to absorb excess vent emissions generated during
road tanker loading. This system has proven to be highly effective in significantly reducing the
emissions of methanol vapour released from the site.
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7.3.5 Fugitive Emissions
The Coogee Methanol Plant has a comprehensive leak detection program in place to detect
fugitive emissions which may result from leaks on valves, flanges, seals etc. Leak detection is
carried out 6-monthly and the results are reported to the EPA on an annual basis.
The following pieces of equipment (in natural gas, synthesis gas, loop gas or methanol
service) are tested/inspected for fugitive emissions on a 6-monthly basis:
鈥? All active valves (manual and actuated) of nominal bore greater that 40 mm.
鈥? All pumps and compressor seals.
鈥? All pipe flanges of nominal bore greater than 40mm.
Results of the leak detection surveys from the past 3 years show that on average, about 2
to 3 minor leaks are detected during each 6-monthly survey. The detected leaks are
usually repaired immediately. Where immediate repair is not possible, the potential
impact of each leak is assessed to ensure that the appropriate action for repair is taken.
Coogee Energy鈥檚 integrated safety system also includes flammable and toxic gas
detectors located throughout the plant to provide early warnings of gas leaks.
7.3.6 Methanol Plant De-bottlenecking Project
The Methanol Plant was originally designed to produce 164 tonnes of methanol per day. Since the
plant was commissioned in 1994, further work has been carried out to improve the technology,
with a particular focus on the reactor (Gas Heated Reformer, GHR), which is the key to the
process advantages of the novel technology used at the Methanol Plant. A number of major design
changes have been conducted on the GHR, including replacement in 1998 with the Advanced Gas
Heated Reformer (AGHR) and most recently, the replacement of the AGHR鈥檚 internals in March
2003. As a result of these changes, the plant is now capable of operation at 140% of original
design capacity at the same process efficiency.
Coogee Energy now intends to 鈥渄e-bottleneck鈥? the Methanol Plant to further increase the plant
capacity up to 180% of original design capacity, while continuing to improve the technology and
process efficiency. To ensure the long term commercial viability of the Methanol Plant, Coogee
Energy has to maintain a continued focus on increasing plant efficiency together with market
expansion.
A number of key equipment items have been identified as bottlenecks to reaching the higher
capacity. Various modification options will be investigated as part of the de-bottlenecking study,
with many projects likely to be considered and potentially implemented. The three following
modification projects have been identified for possible implementation over the next year and are
included as improvement projects in this EIP:
鈥? Pre-heater 鈥? The addition of a further convection bank in the preheater, which is expected
to increase efficiency and recover more waste heat.
鈥? Circulators 鈥? Investigation of the use of a more efficient circulator that uses more modern
technology. Theoretically, the circulation from one of these more efficient
units is the same as that currently achieved by two circulators.
鈥? Pressure Swing Absorption (PSA) Unit 鈥? The installation of a PSA unit will recover
hydrogen from the synthesis gas or loop purge gas to increase the loop
efficiency and reduce the amount of purge gas.
Coogee Energy Pty. Ltd.
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The implementation of these projects will lead to potential energy efficiency gains, with a
corresponding potential reduction in GHG emissions.
7.3.7 Environment Improvement Projects - Greenhouse Gas and Atmospheric Emissions /
Resource Efficiency
Issue Improvement Project Outline Target Priority
Completion
Date
Review the design of the GHR preheater to improve
Greenhouse gas emissions (CO2 End 2003 High
efficiency and reduce greenhouse emissions.
and NOx) from the GHR preheater
Investigate recovering waste heat from the preheater stack. End 2003 High
Re-investigate increasing the efficiency of the loop
Reduce greenhouse gas emissions
circulators to reduce power requirements and improve End 2003 Medium
(CO2, NOx and CH4) from the loop.
process performance.
Investigate hydrogen recovery for the synthesis gas or loop
Reduce greenhouse gas emissions
purge gas to improve the loop efficiency and reduce the April 2004 Medium
(CO2) from the loop.
amount of purge gas.
Reduce greenhouse gas emissions Annual basis 鈥?
Conduct routine monitoring and maintenance to ensure all
(CO2 and NOx) from the boiler / August 2004, Low
steam traps are working correctly.
steam system. 2005 & 2006
Staged replacement of failed standard fluorescent ferro
Ongoing Medium
magnetic tube ballasts with electronic ballasts.
Reduce greenhouse gas emissions
Continue replacing failed standard fluorescent tubes with
(CO2 and NOx) from building and Ongoing Medium
high density triphosphor tubes.
plant lighting.
Investigate lighting options when new electricity contract
Mid 2005 Low
pricing is known (contract is due for renewal in 2004).
Investigate re-routing flare knock-out drum liquid to crude
Reduce greenhouse gas emissions
methanol tank rather than to fusel oil to increase the process End 2004 Low
(CO2 and NOx) from process.
efficiency of synthesis gas generation section.
Minimise methanol loss from topping Re-evaluate the economic viability of installing a further
column reflux drum by reducing water-cooled heat exchanger in the topping column off-gas Mid 2005 Low
operating temperature stream to recover methanol vapour.
Understanding Greenhouse Investigate greenhouse life cycle analysis of methanol
Mid 2004 Low
Emissions production.
Conduct further investigation into the issues surrounding
Stack Monitoring December 2004 High
sampling point EPA-3 as discussed in section 7.3.2.
Investigate why expected efficiency gains from the new
Maintain plant efficiency End 2004 Low
AGHR internals have not been entirely achieved.
7.4 Noise
Noise limits for industry are prescribed in the SEPP (Noise from Industry, Commerce and Trade)
No. N-18. Coogee Energy must also comply with the Occupational Health and Safety (Noise)
Regulations 19929.
The environmental aspect of noise is detailed in Table 4.
Table 5 鈥? Aspect and Impact Table for Noise
Noise
Activity or Environmental Aspect
Plant and Environment
Environmental Element Affected
Noise levels while working in the plant
Potential Environmental Effect or Concern
Local
Extent
A noise survey was conducted in January 1993 at the site of the Methanol Plant, prior to the
construction of the facility. The main contribution to the background noise levels could be
attributed to traffic on Fitzgerald Road. These noise levels were measured from 12:00 noon to
11:00 am with results showing an hourly average of between 41 鈥? 67 dB(A).
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Noise surveys have been conducted at the plant during normal operating conditions:
鈥? The noise level measured by Ofinac Acoustical Engineers in March 1995 gave results of 67
dB(A) at the east perimeter fence (15 metres from Fitzgerald Road), 56 dB(A) at the west
perimeter fence between the native grassland reserve and the methanol storage tanks, and up to
a maximum of 89 dB(A) within the process area.
鈥? The noise measurements made by staff on the footpath on Fitzgerald Road in November 1997
during business hours ranged between 45 dB(A) to 92 dB(A). Readings taken at 3:00 am were
between 54 and 75 dB(A).
The traffic on Fitzgerald Road is the major variable in these measurements. Since commissioning
of the plant, the volume of traffic on Fitzgerald Road has increased due to industrial development
in the area, the duplication of Fitzgerald Road and the opening of the Western Ring Road.
The most recent noise survey was conducted in March 2003 to satisfy the requirements of the
Occupational Health and Safety (Noise) Regulations 1992. The aim of the survey was to assess
the potential noise exposure to Coogee Energy personnel working at the Methanol Plant. The
survey found that there are only a few locations within the plant which have noise levels
exceeding the allowable level of 82 dB(A) for a 12-hour shift. As required, appropriate signage is
displayed in these locations and Coogee Energy supplies hearing protection devices which provide
adequate protection.
A review of the noise measurements taken in the past indicates that there is no measurable
contribution from plant operations to existing background noise levels around the boundary of the
facility. Thus, industrial neighbours are not significantly affected by noise from the Methanol
Plant. Additionally, Coogee Energy is located 2.7 kilometres away from the closest residential
area, so noise from the Methanol Plant is not of significant concern to local residents.
Subsequently, no noise complaints have ever been received by Coogee Energy.
The impact on employees of the noise levels experienced within the plant is minimised through
the following initiatives:
鈥? Noise reduction programs have been implemented and where practicable, equipment within
the plant has been modified to reduce the amount of noise produced.
鈥? In high noise areas within the plant, warning signs are displayed to advise that hearing
protection is required.
鈥? Adequate hearing protection is provided.
鈥? Audiometric testing of all employees is carried out every two years.
Overall, noise is not a significant environmental issue for Coogee Energy and the establishment of
environment improvement projects for noise management is not required.
7.5 Odour
As specified in Coogee Energy鈥檚 Accredited Licence, odours offensive to the senses of human
beings must not be discharged beyond the boundaries of the premises.
Table 6 details the environmental aspect of odour.
Table 6 鈥? Aspect and Impact Table for Odour
Odour
Activity or Environmental Aspect
Atmosphere
Environmental Element Affected
Offensive Odour to site personnel, neighbours,
Potential Environmental Effect or Concern
residents.
Local
Extent
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Coogee Energy has a procedure in place for receiving and investigating odour complaints. Since
commissioning in October 1994, the Methanol Plant has received very few odour complaints and
of the complaints received, all have been shown to originate from other local operations within the
industrial precinct.
A potential cause of odour on site is natural gas. However as described in Section 7.3.5 above,
Coogee Energy has a comprehensive leak detection program in place and gas detectors located
throughout the plant which are designed to identify any such incidents before release off site.
Consequently, odour is not a significant environmental issue for Coogee Energy and the
establishment of environment improvement plan objectives for odour is not required.
7.6 Water and Wastewater
7.6.1 Overview
As the technology used at the Methanol Plant was developed for use in an offshore environment, it
was specifically designed to minimise both raw water requirements and liquid effluent. Water is
primarily used at the Methanol Plant to generate steam for the process and to remove waste heat
from various process streams. The saturator is a key component of the novel technology, with its
main purpose to add steam to the natural gas for the reforming process, however it also
substantially minimises water consumption and liquid effluent by recycling contaminated water
streams through a 鈥渟aturator circuit鈥?. The water leaving the saturator flows through various heat
exchangers and recovers waste heat from process streams before being recycled back to the
saturator. The concentration of contaminants is controlled by blowdown of some of the circulating
water.
In addition water and wastewater minimisation being inherent in the plant design, Coogee Energy
places a continual focus on the reduction of both water usage and trade waste volume. A thorough
awareness of potable water usage throughout the plant means that Coogee Energy can identify
areas with the potential for minimisation. Resources are dedicated on an ongoing basis to
continual water minimisation, with particular attention given to the cooling water system which is
the plant鈥檚 most significant contributor to water loss.
7.6.2 Trade Waste
Wastewater (trade waste) is collected in the trade waste pits (A872A/B). The main sources of
wastewater from the Methanol Plant are:
鈥? Boiler blowdown
鈥? De-aerator blowdown
鈥? Cooling Tower blowdown
鈥? Saturator blowdown
鈥? Demineralisation Plant regeneration waste water
Trade waste discharge is covered under Coogee Energy鈥檚 Trade Waste Agreement with City West
Water (TW No. 40202073, Ref No.4). The Trade Waste Agreement specifies the maximum
allowable discharge limits for various substances. The practice at the Coogee Methanol Plant is to
collect all wastewater and storm water (excluding water from buildings and roadways) directly
into holding pits and analyse a sample of this trade waste in the Methanol Plant Laboratory prior
to discharge. If the sample complies with the trade waste quality requirements specified in the
Trade Waste Agreement, the trade waste is discharged to sewer and ultimately ends up being
treated at the Werribee Treatment Plant. If the wastewater does not meet the City West Water
Coogee Energy Pty. Ltd.
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specification for discharge the Methanol Plant has the facility to process the water on site prior to
discharge to the sewer.
In December 2002, Coogee Energy was issued with its first ever trade waste notice from City
West Water for a breach of the Trade Waste Agreement limit of 200 kg/day for TDS. The increase
in TDS resulted from an initiative to reduce both water consumption and trade waste volume by
increasing the number of cooling water cycles. This increase in cycles subsequently had a
concentrating effect on TDS levels. Due to the prevailing drought conditions, it is important to
continue to conserve water by maximising the number of cooling water cycles.
As Coogee Energy only discharges trade waste approximately once every three days, the overall
average daily TDS mass load was still well below the original 200 kg/day limit. Therefore,
Coogee Energy requested and was granted a variation by City West Water to allow a maximum
load of 500 kg/day for TDS.
7.6.3 Stormwater
As specified in Coogee Energy鈥檚 Accredited Licence, there must be no discharge of contaminated
stormwater from the premises to ground water or water environments.
The plant drainage system is designed to collect any stormwater that has the potential to become
contaminated with methanol or process chemicals, in a series of sumps within the plant. The
contents of these sumps can be pumped to the storm water pit (A868) or the treatment pit (A871).
Stormwater collected in the stormwater pit and treatment pit is discharged to the trade waste
system, with analysis being carried out prior to discharge to the trade waste sewer.
Only rainwater run-off from buildings and roadways is discharged to the stormwater system,
ultimately ending up in local waterways.
A summary of the wastewater system is given below in Figure 15.
Trade Waste Pits (A872A/B) Storm Water Pits (A868)
Boiler Blowdown Process Area
Deaerator Blowdown Bunded Methanol Storage Areas
Cooling Tower Blowdown Tanker load out area
Steam trap blowdown
Saturator Blowdown
Demin Plant regeneration water
Discharge Specifications
< 500 ppm Methanol
< 10 ppm Ethanol
pH 6-10
Treatment Pit (A871)
City West Water
Buildings & Roadways
Discharge route not used
Trade Waste Sewer Storm Water System
Werribee Sewage Treatment Facility Cherry Creek/ Kororoit Creek
Figure 9 鈥? Summary of Wastewater System.
Coogee Energy Pty. Ltd.
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The environmental aspect of water and wastewater is detailed in table 7.
Table 7 鈥? Aspect and Impact Table for Water and Wastewater
Water and Wastewater
Activity or Environmental Aspect
City West Water Sewer
Environmental Element Affected
Western Treatment Plant
Local Creeks and Waterways
Melbourne鈥檚 water resources
鈥? Contamination of treatment facility
Potential Environmental Effect or Concern
鈥? Contamination of local creeks and waterways
(Cherry Creek, Kororoit Creek, Port Phillip Bay)
鈥? Water usage
鈥? Drought
鈥? Volume of waste water produced
Local / Regional
Extent
7.6.4 Past Environmental Performance
Since the commissioning of the Methanol Plant, efforts have been made to reduce the volumes of
both water consumed and wastewater produced. However, it should be noted that as the plant was
specifically designed to minimise water use and effluent, it is difficult to identify improvement
projects that will lead to significant reductions. Figures 10 and 11 illustrate the water usage per
tonne of methanol produced and trade waste discharged per tonne of methanol produced
respectively, on a monthly basis since January 2002.
It is important to note than in the effort to reduce water consumption and trade waste volume,
plant efficiency can be compromised. An example of this occurred in 2000 when Coogee Energy
implemented a water conservation program which involved increasing the number of cooling
water cycles. This increase in the number of cycles caused the concentration of salt levels in the
cooling water to increase significantly. The high salt levels present subsequently increased the rate
of fouling in the heat exchangers that used the cooling water, and thus dropped their efficiency.
This ultimately resulted in loss of heat efficiency and a substantial increase in greenhouse gas
emissions.
In 2002, a similar water reduction initiative was implemented, and remains in place to conserve
water, especially during the period of drought currently being experienced. The cooling water
system is closely monitored to ensure that process efficiency is maintained while maximising the
number of cooling water cycles.
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Water Consumed per tonne Methanol Produced
5.00
methanol produced (kL/tonne
4.50
Water consumed per tonne 4.00
3.50
methanol) 3.00
2.50
2.00
1.50
1.00
0.50
0.00
Jan-02
Feb-02
Mar-02
May-02
Jun-02
Jul-02
Oct-02
Nov-02
Dec-02
Jan-03
Feb-03
Mar-03
May-03
Jun-03
Jul-03
Sep-02
Sep-03
Apr-02
Aug-02
Apr-03
Aug-03
Month
Figure 10 鈥? Monthly water consumption per tonne of methanol produced since January 2002
Trade Waste Volume Discharged per tonne Methanol
Produced
0.90
Trade waste discharged per
tonne methanol produced
0.80
(kL/tonne methanol)
0.70
0.60
0.50
0.40
0.30
0.20
0.10
0.00
Jan-02
Feb-02
Mar-02
May-02
Jun-02
Jul-02
Oct-02
Nov-02
Dec-02
Jan-03
Feb-03
Mar-03
May-03
Jun-03
Jul-03
Sep-02
Sep-03
Apr-02
Aug-02
Apr-03
Aug-03
Month
Figure 11 鈥? Monthly trade waste volume discharged per tonne of methanol produced since
January 2002
As mentioned earlier, stormwater (excluding run-off from roads and buildings) is discharged to
sewer with trade waste. This results in larger trade waste volumes during months of higher
rainfall, rendering it difficult to ascertain the actual trend in the monthly trade waste volumes.
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7.6.5 Environment Improvement Projects 鈥? Water and Wastewater
Issue Improvement Project Outline Target Priority
Completion
Date
Investigate further methods of reducing cooling tower
Reduction of the volume of
wastewater treatment volumes while still maintaining process Mid 2004 Medium
wastewater
efficiency.
Investigate basing the initiation for the back flush of filters in
Reduction of potable water
the demineralisation plant on pressure drop rather than on a March 2004 Low
consumption.
timer.
Reduction of cooling water used to Investigate the installation of an air cooler to cool boiler
End 2003 Medium
cool boiler blowdown blowdown.
7.7 Solid and Liquid Wastes
Solid and liquid wastes encompass the materials that are not recycled within the process,
discharged to the trade waste sewer or storm water system, discharged to the atmosphere or sold
as product. The environmental aspect of solid and liquid wastes is detailed below.
Table 8 鈥? Aspect and Impact Table for Solid and Liquid Wastes
Solid and liquid wastes
Activity or Environmental Aspect
鈥? Soils and Waterways
Environmental Element Affected
鈥? Resources (energy and raw materials)
鈥? Visual
鈥? Extra demand placed on waste disposal
Potential Environmental Effect or Concern
facilities
鈥? Increased pollution
鈥? Incorrect disposal
鈥? Waste of energy and resources
Local / Regional / Global
Extent
Prescribed industrial wastes (PIW) are wastes or mixtures referred to in Regulation 7 of the
Environment Protection (Prescribed Waste) Regulations 199810. The prescribed industrial wastes
produced at the Methanol Plant include lubrication oils, catalyst and laboratory solvents. Only
small amounts of prescribed industrial waste are produced on site, with an average of under 10
consignments of PIW being sent off site per year.
The categories of solids and liquid wastes are listed in Table 9.
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Table 9 - Estimates of the volumes of solid and liquid wastes produced at the Methanol Plant
during the 2002-2003 financial year.
Prescribed
Amount
Waste Type Source Composition Industrial Destination
(Estimate)
Waste
Methanol
Chemical
Laboratory Water
2 m3
Yes recycling or
Solvents
and Plant Hydrocarbons
furnace fuel
Alcohols
Oil recycling to
Process
1 m3
Lubrication oils Yes Environmental
Oil
equipment
Oil
Office and Paper VISY Paper
10 m3
No
Paper
Laboratory Cardboard Recycling
Organic matter
Office and
General
100 m3
Plastic No Land fill
Laboratory
Refuse
Glass
Reprocessed
Nickel to use as soil
17.0 m3
Process Copper Yes
Catalyst nutrients
Alumina
9 m3
Land-fill
Stainless steel
Process No Recycled 20 tonne
Metals
Carbon steel
Prescribed industrial wastes are transported off site for disposal or recycling by contractors that
carry an EPA permit to carry prescribed industrial wastes. The EPA receives written notification
of all prescribed industrial wastes that are collected from Coogee Energy in the form of a Waste
Transport Certificate. This documentation provides details of the type of waste being transported
and of the waste producer, transporter and receiver. Records of all prescribed industrial waste
taken off site are retained.
7.7.1 Environment Improvement Projects - Solid and Liquid Wastes
Issue Improvement Project Outline Target Priority
Completion
Date
Investigate ways of reducing packaging materials used for
Ongoing Medium
Waste Reduction goods delivered to site and report to the CLC.
Recycle metal scraps and waste oil. Ongoing High
Recycle unused chemicals from laboratory to other
End 2003 High
organisations.
Send spent catalyst for re-processing to be used as soil
Ongoing High
nutrients.
7.8 Ground Water
As specified in Coogee Energy鈥檚 Accredited Licence, there must be no discharge of waste or
contaminated stormwater from the premises to ground water or water environments.
The environmental aspect of ground water is detailed in table 10.
Table 10 鈥? Aspect and Impact Table for Ground Water
Ground Water
Activity or Environmental Aspect
Soils and waterways
Environmental Element Affected
Contamination of local soils and waterways
Potential Environmental Effect or Concern
Local / Regional
Extent
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The Coogee Energy site is part of the William Angliss Estate, which was used for grazing cattle
prior to the construction of the plant. The site history indicates that the presence of ground water
contamination due to the prior land usage is unlikely.
As a requirement of the initial EPA Works Approval11 for the site, soil samples were taken from
discrete locations within the site and analysed for the following parameters:
鈥? Total Petroleum Hydrocarbons
鈥? Metals (Arsenic, Cadmium, Chromium, Copper, Lead, Mercury, Nickel and Zinc)
鈥? Organochlorine insecticides.
As expected, all results were found to be below the threshold levels set by the EPA.
At the Methanol Plant, the most likely sources of ground water contamination are from leaking
storage tanks, leaking process lines or chemical spills. To minimise the risk of ground water
contamination in the event of a leak or spill, the main process area of the plant is concreted and
has a series of drains and sumps which collect any liquid run off. Other areas within the plant are
covered with a layer of tar and gravel.
The chemical storage areas in the plant are described in the Table 11.
Table 11 - Chemical Storage areas
Storage area Substance Design and Management
Methanol Tanks located in bunded
Methanol Storage Tanks
area. Bunds either concrete
(G162A/B, G152A/B, G151)
or an impermeable clay.
Regular visual inspections.
Level indicators in tanks with
high and low level alarms.
Mixture of methanol, water and 1000 L capacity underground
Laboratory Solvent Pit
hydrocarbons tank made from 316 stainless
steel.
Diesel Above ground tanks
Diesel Storage Tanks (for
approximately 400 L and
emergency generators and fire
700 L. Regular visual
water pumps)
inspections.
Lubricating oils Oil store has an in-built sump.
Oil Store
Oil store located on concrete
pad. Regular visual
inspections for leaks.
Wastewater Visual inspection for structural
Trade Waste Pits (A871,
integrity.
A872A/B)
7.8.1 Environment Improvement Projects - Ground Water
Issue Improvement Project Outline Target Priority
Completion
Date
Ensuring the integrity of the Review installation of a testing hole to enable monitoring for
June 2004 Medium
underground laboratory solvent pit leaks from the underground laboratory pit.
7.9 Community Right To Know
The community has a right to knowledge about the risks associated with operations at the Coogee
Methanol Plant and Coogee Energy has an obligation to provide this information and respond to
community concerns.
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Coogee Energy鈥檚 commitment to meeting community expectations is demonstrated through our
voluntary participation in the Plastic and Chemical Industries Association of Australia (PACIA)
Responsible Care Program. Through this program, the company is committed to several 鈥淐odes of
Practice鈥?, including that of Community Right to Know. As a requirement of this code of practice,
Coogee Energy must make available to the community (subject to reasonable safeguards such as
commercial confidentiality) information regarding:
鈥? chemicals stored within the premises;
鈥? the processes used at the premises in the manufacture of methanol;
鈥? the transport arrangements for moving chemicals to and from the premises;
鈥? possible, health, safety or environmental effects from the manufacture, storage, transportation
and/or use of chemicals at the premises.12
The Community Liaison Committee is the key forum for communication with the local
community and regulatory authorities. In terms of communicating with broader communities,
Coogee Energy readily provides information to students or the general public relating to a wide
range of aspects of the operations at the Methanol Plant. Coogee Energy鈥檚 web-site
(www.coogee.com.au 鈥? select link to Manufacturing and then Victoria) contains information on
topics such as the methanol manufacturing process and safety features, and provides a MSDS for
methanol. Coogee Energy also actively participates in the PACIA 鈥淥pen Door鈥? program in which
chemical plants within the area conduct open days every three years. Specific plant tours are also
given regularly to secondary school and university students.
7.9.1 Environment Improvement Projects - Community Right to Know
Issue Improvement Project Outline Target Priority
Completion
Date
Continue to provide information to the community as
Ongoing High
Community Right to Know requested.
Quarterly Community Liaison Committee Meetings. Ongoing High
Publish EIP on Coogee Methanol Plant鈥檚 internet site June 2004 Medium
7.10 Product Stewardship
The general community has an expectation that industry gives health, safety and environmental
considerations priority throughout the supply chain and life cycle of products. Accordingly,
Coogee Energy has a responsibility to address these expectations by taking into account the
health, safety and environmental impacts of the product methanol at every stage of its life cycle,
giving consideration to all aspects including the manufacture, distribution, packaging, use,
recycling and disposal of the product methanol. This process of managing the impacts of our
product throughout its life is referred to as Product Stewardship. The environmental aspect table is
shown below.
Coogee Energy鈥檚 commitment to product stewardship is demonstrated through our voluntary
participation in the PACIA Responsible Care Program, which includes a 鈥淧roduct Stewardship鈥?
code of practice. This code of practice requires that the following management practices are
implemented:
鈥? Appropriate education, training and awareness raising of staff, customers, resellers, end-users
and the wider community;
鈥? Suitable labelling and warnings on products;
鈥? Provision of information, advice and assistance;
鈥? Evaluation of downstream users and practices;
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鈥? Supporting R&D in product and process design improvement;
鈥? Providing information on waste minimisation and avoidance;
Supporting reprocessing and waste management.13
鈥?
Coogee Energy is committed to working towards achieving 100% compliance with the PACIA
Product Stewardship Code of Practice. One particular area requiring further work to achieve this
involves the supply of information to customers. For larger, established customers, who have a
general understanding of the hazards associated with handling chemicals, adequate information is
communicated as required. However the supply of information has become a more significant
issue since the commencement of selling drums of methanol to smaller industries that have
minimal experience in dealing with hazardous chemicals. Coogee Energy is responsible for
ensuring that all end users of methanol are aware of its associated hazards and provided with
storage and handling information to minimise potential risks. For this purpose, Coogee Energy has
prepared a Methanol Product Information booklet to provide relevant information about the safe
handling, storage and transport of methanol to the smaller customers.
The drumming of methanol has also introduced packaging considerations, as previously, methanol
was only transported to customers by underground pipeline or road tanker. Coogee Energy aims to
encourage drum recycling, a commitment which is formalised in this EIP.
7.10.1 Environment Improvement Projects 鈥? Product Stewardship
Issue Improvement Project Outline Target Priority
Completion
Date
Create an information booklet and ensure it is sent to small
End 2003 Low
Product Stewardship customers.
Use recycled drums and encourage drum customers to
June 2004 Low
recycle drums.
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8. GLOSSARY
AGHR Advanced Gas Heated Reformer
AQM Air Quality Management
BHP Broken Hill Proprietary Company Limited
CH4 Methane
CH3OH Methanol
CLC Community Liaison Committee
CMP Coogee Methanol Plant
CO Carbon Monoxide
CO2 Carbon Dioxide
CO2-e Carbon Dioxide Equivalent
dB(A) Units of sound pressure level measured in A-weighted decibels
EIP Environment Improvement Plan
EMS Environment Management System
EPA Environment Protection Authority
EPA-1 Licensed Discharge Point 1 - Preheater
EPA-2 Licensed Discharge Point 2 - Boiler
EPA-3 Licensed Discharge Point 3 鈥? Saturator Discharge Separator
ERP Emergency Response Plan
ESH Environment, Safety & Health
GHR Gas Heater Reformer
GHG Greenhouse Gas
g/m3 Units of grams per cubic metre
H2 Hydrogen
MFPSO Methanol Floating Production Storage and Off-take Facility
mg/l Unit of concentration, milligrams per litre.
MSDS Material Safety Data Sheet
NATA National Association of Testing Authorities, Australia
NOX Oxides of Nitrogen
PACIA Plastic and Chemical Industries Association of Australia
pH Measure of acidity or alkalinity of a solution
ppm Units of concentration, parts per million
TDS Total dissolved solids
SEPP State Environment Protection Authority
TOC Total Organic Carbon compounds
VOC Volatile Organic Carbon compounds
VUT Victoria University of Technology
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9. REFERENCES
1
Environment Protection Act 1970 鈥? Act No. 8056/1970
2
AS/NZS ISO 9001:2000 Quality Management Systems - Requirements
3
AS/NZS ISO 14001:1996 Environmental management systems 鈥? Specification with guidance for use
4
National Standard for the Control of Major Hazard Facilities, [NOHSC:1014 (1996)]
5
Accredited Licence Number EA23356 鈥? EPA Licence issued under Section 20 of the Environment Protection Act 1970,
Accreditation granted under Section 26 of the Environment Protection Act 1970
6
National Standards for the Control of Major Hazard Facilities, [NOHSC 1014 (2000)]
7
State Environment Protection Policy (Air Quality Management), gazetted December 2001 (No. S 240)
8
State Environment Protection Policy (Control of Noise from Commerce, Industry and Trade) No. N-1, gazetted June 1989 (No.
S 31) and Variation of State Environment Protection Policy (Control of Noise from Commerce, Industry and Trade) No. N-1,
gazetted October 2001 (No. S 183)
9
Occupational Health and Safety (Noise) Regulations 1992 鈥? Statutory Rule No. 196/1992
10
Environment Protection Authority Prescribed Waste Regulations 1987 鈥? Statutory Rule No. 95/1998
11
EPA Works Approval 1535/4
12
Plastic and Chemicals Industries Association - Responsible Care Community Right to Know Code of Practice, Revision 4,
February 2002
13
Plastic and Chemicals Industries Association - Responsible Care Product Stewardship Code of Practice, Revision 4, February
2002
Coogee Energy Pty. Ltd.
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