Regulatory changes and what that means for regulation of the Orica Botany Transformation Projects. Greg Sullivan NSW Environment Protection Authority

Transcription

1 Community Participation and Review Committee Regulatory changes and what that means for regulation of the Orica Botany Transformation Projects 8 November 2011 Greg Sullivan NSW Environment Protection Authority 1

2 Proposed regulatory changes We are developing a modern, independent EPA making sure that public health and safety is a focus while we protect the broader environment! Photo source: Fairfax Media 2

3 Focus for EPA regulation of Orica: 1. Continue investigation into mercury vapour incident on 27 September Ensure mercury contamination is safely addressed 3. Finalise remediation of the Car Park Waste 4. Ensure ongoing clean-up of the groundwater 5. Input to the ongoing management of the HCB waste 3

4 Discussion and community views 4

5 OEH Update on HCB Matters Community Participation and Review Committee 8 November 2011 James Goodwin Sydney Industry 1

6 Overview of Presentation Carpark Waste Remediation Project - Timeline - Commercial Operations - Annual Return - Site inspections - Next steps 2

7 Timeline since last meeting 18/8/11 Initial Pre-Test results received Proof of Performance Tests 23 to 27 August 16/9/11 Licence variation issued to include additional requirements Mid-September 13 October Develop licence conditions for commercial operations 20/10/11 Licence variation to reflect updated Liner Management Plan 8 Nov August September October November 9 August 23/8/11 OEH provides formal comments on Proof of Performance Test Plan 13/9/11 Draft Proof of Performance Test results received for all three tests 30/9/11 Final report on baseline Mercury Control Trials received 14/10/11 Licence variation issued to permit commercial operations 3

8 Commercial Operations Stringent conditions imposed, including - maximum feed rate of 27 tonnes per hour - minimum exit gas temperature from Primary Treatment Unit of 445 degrees Celsius - mercury limit of 0.2 milligrams per cubic metre - monitoring requirements for contaminated feed soil - reporting of excursions above plant parameters 4

9 Annual Return Three non-compliances reported 1. Not measuring flow at Thermal Oxidiser 2. Two Carbon Monoxide data points outside range 3. Residence time on start-up less than 2 seconds - Licence amended for (1) - (2) and (3) instrumentation issues 5

10 Site inspections One announced (21 September) and one unannounced (7 November) Building on previous six inspections 6

11 Next Steps - Pro-active and re-active regulation of commercial operations - Licence variation if planning approval granted for treatment of other materials 7

12 Questions? 8

13 CPWE PROJECT UPDATE CPRC Meeting 8 November 2011 Joshua Van Der Heiden

14 CPWE PROJECT UPDATE CPoP program is now complete and OEH has approved full scale treatment operations In addition to the Continuous Emissions Monitoring System there have been eight full suite stack tests undertaken on the DTD plant and all results are well within OEH limits Excavated, transported and stockpiled 33,500m3 from the Excavation Soil Building to the Feed Soil Building and treated 52,200 tonnes in the DTD By the end of this week we will have completed excavation of approximately 2/3rds of the projected volume Excavation of Stage 1 will be complete this week with excavation of Stage 2 (remaining 1/3 of the CPWE) commencing in mid December Thermal Treatment likely to be complete in March 2012 Project demobilisation likely to be complete in May 2012

15 CPWE PROJECT UPDATE Environmental Monitoring Update Dust Continuous logging, attended monitoring and dust deposition gauges Over half a million measurements taken in the three month period 5 exceedances against the EPA goals detected: Three at Hensley Athletics Field not attributable to the CPWE project due to heavy fog, lawn mowing on Hensley and smog Two on the CPWE project (dust deposition gauges) due to inappropriate siting of the equipment (inside the active treated soil stockpile area and far from the site boundary) Noise No noise impact detected from CPWE activities

16 EXCAVATION SOIL BUILDING LOOKING WEST

17 EXCAVATION SOIL BUILDING LOOKING EAST

18 CPWE Remediation Project Independent Expert Panel Update Peter O Dea 8 November 2011

19 CPWE Remediation Project Independent Expert Panel Update IEP Members: Dr John McCracken engineering Dr Chris Clunies-Ross air emissions Dr Peter Nadebaum environment Prof Brian Priestly health Current Task: Review and comment on Commissioning and Proof of Performance (CPoP) Trials 8 November 2011

20 IEP Involvement throughout CPoP Process IEP, OEH, Orica and Thiess Workshop - November 2010 Reports on Clean Soil Shakedown, Contaminated Soil Shakedown & Mercury Control Trials IEP, OEH, Orica and Thiess Workshop - July 2011 IEP members provided reports to the CPRC in July endorsed 400 o C as minimum soil treatment temperature - agreed no additional mercury control trials were necessary - outstanding query about mass balance & request for fugitive emission data Since the August CPRC meeting, Orica has provided the following to the IEP: - Mercury Ambient Air Monitoring data (checking fugitive emissions) - Pre-Test and PoP Trial reports - Final Mercury Controls Report (finalising mass balance) - OEH Licence Amendments 8 November 2011

21 IEP Feedback since August Meeting Dr Clunies-Ross (who also conducted sampling) - no comments or concerns Prof Priestly - no comments or concerns Dr Nadebaum - queried a high mercury reading during the ambient monitoring Orica explained to his satisfaction that the sample was from inside the process equipment, not in the open air. No further comments Dr McCracken said the achieved DTD destruction efficiency represents an acceptable and best practice environmental outcome and had 5 requests for information or comment 8 November 2011

22 Dr McCracken Requests 1. Treated soil data for contaminants other than HCB, HCBD and Mercury provided summary (details had been given to OEH and Site Auditor) 2. Commentary on effect of ambient wind conditions on fugitive emissions. advised that DTD has instruments to prevent positive pressure which might cause fugitive emissions 3. Evidence that DTD pressure instruments had been calibrated provided commissioning records 4. Additional ambient air monitoring for mercury, not on a windy day tests will be repeated 1. Comments on why scrubber water discharges are not completely consumed in the pugmill and on what happens to mercury and other contaminants normally all goes to pugmill, occasionally some goes to Water Treatment Plant, where mercury (30 ppb) and other contaminant limits have always been met 8 November 2011

23 Update on Other Soils to DTD The prospect of processing other contaminated soils from the BIP, Pacific National (now called Asciano) and Southlands in the DTD was first discussed with the CPRC at the November 2006 meeting. Status: - The DoPI has approved processing of 1,000 t (600 m 3 ) of soil and concrete from the HCB stores - Orica has sought approval to process 160 m 3 of soil from the Asciano embankment - Orica has sought approval to process 1,200 m 3 of soil from Southlands Material has to be processed to the requirements of the Environment Protection Licence: Maximum 27 tonnes/hour Maximum 4,000 mg/kg HCB + HCBD in feed to DTD Compliance with Clean Air Regulations Specified Sample Frequency, etc. 8 November 2011