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FINAL
COMPLIANCE AUDIT REPORT
BLUESCOPE STEEL (AIS) PTY LTD FIVE ISLANDS ROAD
PORT KEMBLA NSW 2505
FEBRUARY 2012
This report has been prepared to present the findings of the audit carried out and no responsibility is accepted for its use in any other context, or for any other purpose.
© 2012 State of NSW and Environment Protection Authority
The State of NSW and the Environment Protection Authority (EPA) are pleased to allow this material to be reproduced in whole or in part for educational and non-commercial use, provided the meaning is unchanged and its source, publisher and authorship are acknowledged.
The EPA has compiled this publication in good faith, exercising all due care and attention. No representation is made about the accuracy, completeness or suitability of the information in this publication for any particular purpose. The EPA shall not be liable for any damage which may occur to any person or organisation taking action or not on the basis of this publication. Readers should seek appropriate advice when applying the information to their specific needs.
Published by: Environment Protection Authority 59–61 Goulburn Street, Sydney PO Box A290, Sydney South 1232 Phone: (02) 9995 5000 (switchboard) Phone: 131 555 (environment information and publications requests) Fax: (02) 9995 5999 TTY users: phone 133 677, then ask for 131 555 Speak and listen users: phone 1300 555 727, then ask for 131 555 Email: info@environment.nsw.gov.au Website: www.epa.nsw.gov.au
Report pollution and environmental incidents Environment Line: 131 555 (NSW only) or info@environment.nsw.gov.au See also www.epa.nsw.gov.au
ISBN 978 1 74293 607 9 EPA 2012/0330 April 2012
EXECUTIVE SUMMARY
An Environment Protection Authority (EPA), Compliance Audit was undertaken at the BlueScope Steel (AIS) Pty Ltd Port Kembla Steelworks. The site was audited as part of a state-wide program of audits focusing on the management of major environmental risks associated with the activities undertaken at the site. The audit also focussed on emergency management procedures to be used by the licensee in the event of an incident occurring that is or is likely to impact on the environment or on the local community. The main objectives of the audit were to assess compliance with the requirements of Environment Protection Licence 6092 relating to the management of major environmental risks and emergency management planning, and to recommend an action program to be implemented by the licensee to address any non-compliance identified during the audit.
Assessment of compliance was undertaken using information collected during a detailed audit inspection, information supplied by the enterprise, and a review of records and documentation relating to the premises. The procedures and protocols for conducting compliance audits are detailed in the EPA Compliance Audit Handbook. The audit inspections were carried out by officers of the EPA on 12 and 13 December 2011.
The findings of the audit indicate that the enterprise was not complying with some of the conditions attached to Environment Protection Licence 6092 issued under the Protection of the Environment Operations Act 1997.
The non-compliance related to:
Loss of containment of COG main residues and the potential for contamination of land and groundwater
The following issues of concern were identified through further observations:
Loss of containment of tar in the Gas Holder area with the potential to migrate to the Main Drain and into the harbour
Liquid (Water) discharge from areas around the BOS Furnaces (including Waste water Treatment Plant and Slag Yard) with the potential to go to Allan’s Creek
Procedures, processes and equipment for managing major environmental pollution incidents
A risk assessment of non-compliances is used to colour code non-compliances according to their environmental significance and an action program has been developed. The action program includes a timeframe for non-compliances to be addressed to ensure the licensee deals with issues raised through the audit process in a timely manner (Table 4.1).
While the risk assessment of non-compliances is used to prioritise actions to be taken, the EPA considers all non-compliances to be important and licensees must ensure that all non-compliances are addressed by the due date specified in the Action Program.
TABLE OF CONTENTS
1.0 ............................................................................................................ 1 INTRODUCTION
1.1 .......................................................................................................... 1 Audit Objective
1.2 ...................................................................................................... 1 Scope of the Audit
1.3 ......................................................................... 1 Audit criteria, evidence and findings
1.4 .............................................................................. 2 Premises and Process Description
1.5 ........................................................... 2 Statutory Instruments Issued to the Enterprise
1.6 ....................................................................... 3 Risk Assessment of Non-compliances
2.0 .............................................................................. 4 ASSESSMENT OF COMPLIANCE
2.1 ................................................................................. 4 Compliance with Audit Criteria
Table 2.1 Assessment of Compliance with Environment Protection Licence No. 6092 ....... 5
3.0 ...................................................................................... 30 FURTHER OBSERVATIONS
4.0 .................................................................................................... 32 ACTION PROGRAM
Table 4.1 Action Program – Environment Protection Licence No. 6092 .......................... 32
APPENDICES
Appendix A Licensee Response to Draft Report
Appendix B Letter covering licensee’s response to Draft Compliance Audit Report
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
FINAL/FIL11/9621/ DP 1 Environment Protection Authority
1.0 INTRODUCTION
An Environment Protection Authority (EPA), Compliance Audit has been undertaken at the BlueScope Steel (AIS) Pty Ltd Steelworks at Port Kembla. The site was audited as part of a state-wide program of audits focusing on the management of major environmental risks associated with the activities undertaken at the site. The audit also focussed on emergency management procedures employed by licensee in the event of an incident occurring at the site that is or is likely to impact on the environment or on the local community. The audit inspections were undertaken on 12 and 13 December 2011.
The procedures and processes for conducting EPA Compliance Audits are detailed in the Compliance Audit Handbook, which can be accessed on the EPA website at http://www.environment.nsw.gov.au/resources/licensing/cahandbook0613.pdf.
1.1 Audit Objective
The objectives of the audit were
- to determine whether the enterprise is complying with environment protection licence requirements in relation to the audit scope and criteria; and
- to outline a time frame for follow-up action to address any non-compliances identified during the audit.
1.2 Scope of the Audit
The scope of the audit is limited to the examination of the activities undertaken at BlueScope Steel (AIS) Pty Ltd, in relation to the management of major environmental risks.
The temporal scope adopted for assessment of compliance is:
- The day of the audit inspection for assessing compliance with Operating Conditions, relating to the management of major environmental risks and emergency management planning; and
- 12 months prior to the end of the audit inspection for assessing compliance with any Monitoring, Recording and Special Conditions and Pollution Studies and Reduction Programs relating to the audit scope.
1.3 Audit criteria, evidence and findings
Audit criteria (the requirements against which the auditor compares collected audit evidence) are the Conditions attached to Environment Protection Licence Number 6092 issued under the POEO Act to BlueScope Steel (AIS) Pty Ltd, in relation to the management of major environmental risks.
Audit criteria may include any document referred to by the licence, or relevant to a particular condition of the licence.
Audit evidence was collected during discussions with site personnel, examination of documentation provided by the licensee and/or contained on EPA files, together with observations made during the audit inspection.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
FINAL/FIL11/9621/ DP 2 Environment Protection Authority
Findings of non-compliance with licence conditions are summarised in table 2.1. An Action Program provides a time frame for follow-up action necessary to comply with the licence condition concerned.
1.4 Premises and Process Description
BlueScope Steel (AIS) Pty Ltd operates an integrated steelworks situated on a 760 hectare site approximately 80 kilometres south of Sydney on the NSW south coast at Port Kembla. The facility is located within the Wollongong local government area and is surrounded by industrial and residential premises.
The Port Kembla Steelworks is currently a 2.6 million tonne per year integrated steelworks. Some of the facilities at the site include: Shipping and rail operations, sinter plant, oxygen generation plant, lime kiln, coke ovens, blast furnaces, basic oxygen steelmaking furnaces, continuous slab casters, hot strip mill and plate mill.
BlueScope Steel has an extensive Emergency Management System. Small incidents are managed within one of the 65 departmental emergency plans. When an incident is beyond the resources of a single department or has wider implications across the site, the emergency response can be escalated.
1.5 Statutory Instruments Issued to the Enterprise
The EPA has issued the following statutory instruments to the enterprise:
Licence number 6092 issued under the Protection of the Environment Operations Act 1997.
The scheduled activities undertaken at the premises are Coke production, Iron or steel production (iron ore), Cement or lime handling, Agricultural fertiliser (inorganic), Generation of electrical power from gas, Coal works, Scrap metal processing, Waste storage (other types of waste), Recovery of general waste, Recovery of waste tyres, Mineral processing, Waste storage (waste tyres), Cement or lime production, General chemicals storage , Crushing, grinding or separating, Railway systems activities , Shipping in bulk and Dangerous goods production. The fee scale category of Iron or steel production (iron ore) is > 0 tonne produced.
The anniversary date for the licence is 1 July.
A copy of Licence 6092 can be accessed through the EPA online public register at: http://www.environment.nsw.gov.au/prpoeoapp/searchregister.aspx
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
FINAL/FIL11/9621/ DP 3 Environment Protection Authority
1.6 Risk Assessment of Non-compliances
The significance of any non-compliances identified during the audit process are categorised. Following risk assessment of non-compliances, an escalating response relative to the seriousness of the non-compliance is determined to ensure the non-compliance is addressed by the enterprise.
The risk assessment of non-compliances involves assessment of the non-compliance against two criteria; the likelihood of environmental harm occurring and the level of environmental impact as a result of the non-compliance. After these assessments have been made, information is transferred into the risk analysis matrix below.
Likelihood of Environmental Harm Occurring
Certain Likely Less Likely
High Code Red Code Red Code Orange
Moderate Code Red Code Orange Code Yellow
Lev
el o
f E
nvi
ron
men
tal I
mp
act
Low
Code Orange Code Yellow Code Yellow
The assessment of the likelihood of environmental harm occurring and the level of environmental impact allows for the risk assessment of the non-compliance via a colour coding system. A red risk assessment for non-compliance denotes that the non-compliance is of considerable environmental significance and therefore must be dealt with as a matter of priority. An orange risk assessment for non-compliance is still a significant risk of harm to the environment however can be given a lower priority than a red risk assessment. A yellow risk assessment for non-compliance indicates that the non-compliance could receive a lower priority but must be addressed.
There are also a number of licence conditions that do not have a direct environmental significance, but are still important to the integrity of the regulatory system. These conditions relate to administrative, monitoring and reporting requirements. Non-compliance of these conditions is given a blue colour code.
The colour code is used as the basis for deciding on the priority of remedial action required by the licensee and the timeframe within which the non-compliance needs to be addressed. This information is presented in the action program alongside the target/action date for the non-compliance to be addressed.
While the risk assessment of non-compliances is used to prioritise actions to be taken, the EPA considers all non-compliances are important and licensees must ensure that all non-compliances are addressed as soon as possible.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
FINAL/FIL11/9621/ DP 4 Environment Protection Authority
2.0 ASSESSMENT OF COMPLIANCE
2.1 Compliance with Audit Criteria
Compliance was assessed against the licensing requirements of the POEO Act, and the requirements of Environment Protection Licence Number 6092 relating to the audit scope and criteria.
Assessment of compliance was undertaken by a detailed site inspection and review of all records and documentation relating to the audit scope and criteria as required by the licence issued to the licensee.
The findings of the audit indicate that the conditions of the environment protection licence, relating to the audit scope were being complied with.
Details of assessment are presented in Table 2.1.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
Table 2.1 Assessment of Compliance with Environment Protection Licence No. 6092
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
O Operating Conditions
The audit assessment is based upon evidence relating to the period limited to on the day of the audit inspection. Managing major environmental risks associated with water / land pollution O1.1 Licensed
activities must be carried out in a competent manner
Yes
Identification of Major Environmental Risks
The licensee has identified major environmental risks associated with the pollution of stormwater at the premises. This includes pollution of stormwater from the following sources:
Potential for release of firewater to stormwater during fire fighting activities.
Potential for pollution by Coke Ovens Gas (COG) condensate overflowing into the drain system and into Port Kembla Harbour
Loss of containment of COG main residues and subsequent environmental contamination
Potential for loss of containment of tar in the Gas Holder area, and possible migration to Main Drain and into the harbour
Potential for an oil spill to occur in Energy Services Department resulting in discharge of oil into works drains and the harbour
Potential for stormwater to become polluted from discharges of liquid (Water) from areas around the Basic Oxygen Steelmaking (BOS) Furnaces (including Waste water Treatment Plant and Slag Yard).
The auditors did not identify any other major environmental risks during the site inspection that had not already been identified by the licensee.
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 5 Environment Protection Authority
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 6 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Use of controls to minimise the Major Environmental Risks Identified - Release of firewater to stormwater
The licensee has controls in place to manage the major environmental risks identified such as:
The coke ovens recovery basin has capacity to trap contaminated fire water from a fire in the coke ovens/gas processing area
Chemical storage tanks are equipped with secondary spill containment
North Gate Drain Gross Pollutant Trap helps remove floating and settleable contaminants
Some drainage lines lead to engineered depressions where run-off waters can seep away. This enables some filtration of contaminants prior to discharge to the receiving waters
Training of staff in the use and managements of controls and their roles in emergency response (Drains are marked to indicate if they connect to the harbour; inlets can be sandbagged to filter fire water)
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes:
Monitoring the water level in the coke ovens recovery basin
Undertaking routine inspections/maintenance/calibration of monitoring and control equipment
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 7 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Use of controls to minimise the Major Environmental Risks Identified - Pollution caused by COG condensate overflowing into the drain system and into Port Kembla Harbour
The licensee has controls in place to manage the major environmental risks identified such as:
Seal pot discharge points have installed concrete collection wells
A regular seal pot collection well pump out regime is in place for all COG seal pots (the pump out is returned to the coke works biological treatment plant)
The coke ovens recovery basin provides backup containment for leaks and spills from the coke ovens and gas processing areas
Waters from the biological treatment plant and coke ovens recovery basin can be re-used in the hot coke quenching process
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Biological treatment plant effluent is tested daily to monitor the level of treatment performance
Testing and calibration of equipment (incl. instrumented equipment)
Monitoring water quality at the premises licensed discharge points (minimum 8 day cycle)
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 8 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
No
Code Red
Use of controls to minimise the Major Environmental Risks Identified - Loss of containment of COG main residues and subsequent environmental contamination
The licensee has controls in place to manage the major environmental risks identified such as:
A variety of steel and fibreglass tanks/containers are used for the storage of COG main residues. However accelerated corrosion from steel storage tanks partially buried in slag material is likely to increase the risk of liquids leaking from the containers. The valve housing of another steel storage tank was in contact with the slag base material potentially increasing the risk of corrosion damage to the valve at the lowest point of the storage tank. An indication of spillages onto the slag base was observed in one area (Please refer to the photograph following Table 2.1).
Liquids in the residues are permitted to evaporate so that the material is maintained in a solid form for secure handling and reduced risk of spillage
All open-top tanks are fitted with rain covers in an attempt to prevent the ingress of rainwater. However it was identified that some of the rain covers fitted to open top tanks may not have extended adequately beyond the sides of the tank to exclude wind blown rain from entering the tank
In two of the four areas where COG main residues are stored secondary spill containment was provided so that any leaks and/or spills could be recovered without causing pollution
The EPA is concerned that any loss of containment from the tanks in three of the four storage areas has the potential to pollute surface, groundwater and soil.
The licensee must implement controls and
monitor the effectiveness of those controls to
minimise the likelihood of discharge of stored COG main residues from the
site.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 9 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of some of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Inspection on tanks and containment structures to detect leaks and spills
Monitoring integrity to detect infiltration into the ground at three of the four storage areas is not undertaken.
The frequency of tank integrity testing is not considered adequate to detect loss of containment
Note: Condition U15 of the licence requires the development of a coke ovens gas mains solids management plan which details appropriate storage and disposal methodologies that will be implemented for current and future coke ovens gas mains solids. (See below for Pollution Reduction Programs (PRP))
Yes Use of controls to minimise the Major Environmental Risks Identified - Loss of containment of tar in the Gas Holder area, and possible migration to the Main Drain and into the harbour
The licensee has controls in place to manage the major environmental risks identified such as:
Tar make-up tanks have secondary containment installed to collect leaks and spills
A concrete lined collection pit is installed to intercept tar leakage at the gas holders
Absorbent oil booms are installed in the main drain for the interception and
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 10 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
removal of floating contaminants
Some spillages can be diverted to and contained the coke ovens recovery basin for subsequent removal
Please refer to Further Observations. Monitoring the effectiveness of the controls used by the licensee to manage the
Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Frequent inspections and pump-out of tar collection sumps and Main drain oil booms
Water quality monitoring at the licensed discharge points (minimum 4 day cycle)
Note: Condition U20 of the licence requires investigation of every activity with potential to cause PAH (Polycyclic aromatic hydrocarbons) contamination to the soils and groundwater at the Gas Holder Compound. The report of the outcomes of the investigation was due on 31 December 2011 and therefore beyond scope of this audit.
It is noted that this report has been provided.
Use of controls to minimise the Major Environmental Risks Identified - Oil Spill incident occurring in the Energy Services area resulting in discharge of oil into the drain system and into Port Kembla Harbour
The licensee has controls in place to manage the major environmental risks identified such as:
Spills directed to the salt water inlet channel skimmers for collection
Emergency boom available as a backup if required
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 11 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Oil tanks monitored for loss of containment
Frequent inspections and maintenance of oil skimmer
Integrity checks – tanks
Use of controls to minimise the Major Environmental Risks Identified - Liquid (Water) discharge from areas around the BOS Furnaces (including Waste water Treatment Plant and Slag Yard) with the potential to go to drain
The licensee has controls in place to manage the major environmental risks identified such as:
Waste water Treatment Plant Secondary/tertiary containment collects leaks and spills which are then pumped to the process tanks
Sensors detect pipeline pressure drop to indicate a loss of containment. In the event of an alarm the licensee can isolate the pipe and recover the spillage by pumping back to the treatment plant storage vessels
Please refer to Further Observations.
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Monitoring, alarms and trips (levels, pressures)
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 12 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Testing and calibration of equipment (incl. instrumented equipment)
Integrity checks – tanks
Visual checks – 4 hourly inspections (no leaks occurred in the previous 12 months)
Managing major environmental risks associated with air pollution
Yes Identification of Major Environmental Risks
The licensee has identified the major environmental risks associated with the pollution of air at the premises. This includes pollution of air due to:
Loss of containment (LOC) of coke ovens gas
Coke ovens Waste Heat stack emissions
Emissions resulting from the loss of electrical power to the coke ovens batteries
High voltage loss of electric power to the Steelworks
Hazards associated with loss of functionality of coke ovens exhausters (including resulting in a fire and/or explosion)
Air emissions linked to No. 5 blast furnace operational scenarios
Plant-wide kish emissions to the atmosphere
Fugitive dust emissions at the Desulphurisation Treatment plant
Machine Scarfing - Iron Oxide fumes escaping to atmosphere via the Scarfer stack
Fugitive dust emissions from the Port Kembla Recycling Area and other Alliances and Recycling managed areas
The auditors did not identify any other major environmental risks during the site inspection that had not already been identified by the licensee.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 13 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Use of controls to minimise the Major Environmental Risks Identified - LOC of coke ovens gas
The licensee has controls in place to manage the major environmental risks identified such as:
Written procedure ensures charging of the oven follows the correct sequence
Charging operations are interlocked, to assist the driver of the charger car to check for leaks, correctly complete a step in the sequence prior to moving to the next step in the sequence
Steam is introduced into the valve box to establish a draft into the collector main
Regular surveying of the oven tops ensures correct alignment of the charger car with the oven lids thereby assisting with the control of leaks
All mechanisms are included in a maintenance strategy (e.g. valve box and lid seal cleaning)
Competency training together with regular refresher training of operators
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
CCTV in the charger car assists the operator to confirm standpipe caps are closed and/or not emitting raw COG. CCTV is also used to assist control room operators in detecting any leaks of COG
Alarms inform the driver of the charger car of any problem with the mechanisms
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 14 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
and/or sequence of charging the ovens
Alarm prioritisation procedure at the Coke ovens control room
Visual checks – confirm the operation of alarms
Alarms are logged for trend analysis which informs maintenance plans
Written Procedures (compliance sign-off; regular management review)
Use of controls to minimise the Major Environmental Risks Identified – Coke ovens Waste Heat stack emissions
The licensee has controls in place to manage the major environmental risks identified such as:
Managing carbon growth on oven brickwork to reduce the escape of raw COG into the oven flues
Refractory Repair Team – Ceramic welding
Back scatter meters in the stacks, with alarms in the control room help identify ovens in need of maintenance/repair
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Internal inspections of ovens informs the repair frequency required
Monitoring (additional temperature checks where coking time may have been extended)
Fortnightly review of alarm trends to inform repair scheduling for problem ovens
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 15 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Quarterly stack emissions testing
Monitoring instruments are on a monthly maintenance and calibration schedule.
Visual inspections (CCTV can monitor stack emissions)
Use of controls to minimise the Major Environmental Risks Identified - Emissions resulting from the loss of electrical power to the coke ovens batteries
The licensee has controls in place to manage the major environmental risks identified such as:
Batteries are fitted with emergency flares to reduce the amount of contaminants being emitted under emergency conditions
Emergency flares have multiple backup igniters to help ensure flaring of raw COG
Un-interruptible Power Supply (UPS) backup power for the control room and emergency igniters to start raw COG flaring
Maintenance and checks of equipment
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Written Procedures (controlled copies)
UPS – Annual load test and 5 year battery replacement
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 16 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Use of controls to minimise the Major Environmental Risks Identified – High Voltage loss of electric power to the Steelworks
The licensee has controls in place to manage the major environmental risks identified such as:
5 incoming high voltage supplies and 4 substations designed to provide backup in the event of a loss of an incomer as well as minimising the parts of the plant affected by a power outage
All electrical circuits have protection designed to isolate a fault from the bulk of the distribution network
Backup systems – including un-interruptible power supplies at various departments
Maintenance and inspection regime
Diesel back-up generators installed to provide safe shutdown, run alarms and small pumps, prevent oil fires and LOC
Flares are installed for the purpose of reducing the concentrations of contaminants released to the atmosphere
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Written Procedures (controlled copies)
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 17 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Monitoring, alarms inform control room
Thermal cameras monitor flare igniters
Maintenance schedule for flare igniters
Testing regime in place for monitoring systems
Use of controls to minimise the Major Environmental Risks Identified - Hazards associated with loss of functionality of coke ovens exhausters (including resulting in a fire and/or explosion)
The licensee has controls in place to manage the major environmental risks identified such as:
3 of the 5 exhausters draw gases from the coke ovens to the gas processing plant. 2 back-up exhausters are maintained in standby mode
Backup flushing liquor cooling water pumps are provided
A diesel generator is provided to supply backup power to the cooling water pumps in the event of a loss of power
A second layer of backup is provided by steam driven pumps
Emergency raw gas bleeders on the coke ovens, flare excess gas if the gas processing plant fails in order to help reduce the concentration of contaminants in emissions to the atmosphere
The Gas Processing control room is provided with an un-interruptible power supply
Flammable liquid storage tanks at the gas processing area are fitted with fixed rooves to reduce the risk of fire
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 18 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
o Sensors and alarms on tanks (high and high-high)
o Sensors and alarms in tank farm bund sumps inform the control room in the event of leaks or spills from tanks
o Pressure relief and pressure venting
To coke battery exhausters or
To waste heat stack for dispersion
Control of ignition sources (open flame, smoking, Permit to Work)
Smoke detectors in all switch rooms
Gas detectors (benzene and carbon monoxide) inform the control room of any loss of containment of vapours
A watcher is present to oversee all hot work
Fire fighting systems – including foam and fixed deluge sprays at the gas processing truck loading bay
Change management procedures are in place for process changes
Spill equipment is available for use in the clean-up of minor spills at that site.
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Monitoring, alarms, inform the control room about cooling water availability
Regular maintenance ensures the reliability of cooling water low flow alarms
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 19 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Fortnightly testing of the backup power generator
Un-interruptible power supply – Annual load test and 5 year battery replacement
Regular bund sump detector simulation testing
Testing and calibration of equipment (incl. instrumented equipment) (3 monthly)
Integrity checks – storage tanks
Training – basic fire training on a 2 year cycle
Fire scenario training
Use of controls to minimise the Major Environmental Risks Identified - Air emissions linked to No. 5 blast furnace operational scenarios
The licensee has controls in place to manage the major environmental risks identified such as:
Written procedure to respond to a furnace cooling trend
4 top bleeders release pressure in the furnace vessel to protect against structural damage of the furnace vessel
Formal handover practice involves upper management on site as well as the involvement of extra personnel during abnormal operations (e.g. start-up/shut-down scenarios)
Recirculated off-gas scrubbing system reduces the risk of contaminated waste water discharges
Flammable gas pressure built up can be flared by the inter works gas distribution system to reduce emissions to the atmosphere
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 20 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Emergency header tank fitted to the top of the furnace supplies cooling water to help maintain the integrity of the furnace vessel
Diesel power generator back-up system for critical control room functions
Furnace design and setup to fail to a safe condition
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Furnace pressure tests conducted post refractory reline
Bleeder trip tests conducted on a 4 year cycle
Maintenance regime for the diesel backup generator to ensure serviceability
Use of controls to minimise the Major Environmental Risks Identified - Plant-wide kish emissions to the atmosphere
The licensee has controls in place to manage the major environmental risks identified such as:
Dust extraction hoods installed at the hot metal dumping pits to collect kish when molten iron is poured from the torpedo ladle into the launder
Written procedure ensures risk of emissions can be reduced and high kish emitting activities can be slowed and/or stopped
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 21 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Baghouse/Dust catchers/Cyclones
Written procedure to ensure iron dumping does not occur solely due to industrial action
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Written Procedures (e.g. monitoring kish pot temperatures prior to tipping)
Kish complaints monitoring and investigation procedure
Manual emission ranking and reporting system for a range of potential kish emitting activities
Maintenance schedule (e.g. baghouse)
Use of controls to minimise the Major Environmental Risks Identified - Fugitive dust emissions at the Desulphurisation Treatment plant
The licensee has controls in place to manage the major environmental risks identified such as:
Building enclosure with hood and ducting over the hot metal rail wagons (torpedo ladles)
Spillage prevention procedures (e.g. check level of iron in the ladle before commencement; limiting the lime injection rate; and the height of the injection
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 22 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
lance)
Bag house to filter the particles from any fume generated during the process prior to discharge to the atmosphere
Treatment process and the baghouse are interlocked to prevent the process occurring without suction to the bag filters
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Monitor pressure across the inlet and outlet of the bag house
Alarms on the bag house fan inform the control room of any problem with suction prior to commencing the process
Use of controls to minimise the Major Environmental Risks Identified - Machine Scarfing - Iron Oxide fumes escaping to atmosphere via the Scarfer stack
The licensee has controls in place to manage the major environmental risks identified such as:
Electrostatic precipitator with 6 cells to reduce process emissions prior to discharge to the atmosphere
Written procedure (covering the removal of cells in the electrostatic precipitator dust collector for maintenance)
Water sprays at the scarfing lance to knock down heavy particles into a scale
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 23 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
collection pit
Scarfing process is interlocked to ensure the precipitator and water sprays operate concurrently
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Maintenance schedule on electrostatic precipitator (Daily electrode voltage test)
Control room CCTV/visual checks and emission rating and recording system for emissions trend review
Use of controls to minimise the Major Environmental Risks Identified - Fugitive dust emissions from the Port Kembla Recycling Area and other Alliances and Recycling managed areas
The licensee has controls in place to manage the major environmental risks identified such as:
Water carts and vacuum sweeping of sealed roads assist with the reduction of traffic-generated dust emissions
Vegetative stabilization of bare areas to reduce the generation of wind-blown dust emissions
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 24 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Fixed sprays in some areas where materials are stockpiled
Backup systems (water supply and pumps)
Truck and wheel wash facilities to help reduce the drag-out of particles onto sealed roads from vehicles exiting un-sealed areas of the site
Monitoring the effectiveness of the controls used by the licensee to manage the Major Environmental Risks
The licensee monitors the effectiveness of the controls used to manage the major environmental risks identified at the site. Monitoring undertaken by the licensee includes the use of:
Written Procedures
Maintenance schedule on plant and equipment
Monitoring and reporting system for dust emissions
Training
Managing Major Environmental Pollution Incidents
Yes Procedures, processes and equipment for managing major environmental pollution incidents
The licensee has procedures, processes and equipment in place to manage major environmental incidents. The procedures include;
Documentation systems and procedures within the Emergency Response Plan to deal with all types of incidents and keeping the Plan onsite - Please refer to Further Observations
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 25 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
Evacuation of non-essential personnel and notification to Senior Licensee management
Notification to relevant agencies such as NSW Fire Services, Port Kembla Port Corporation (including Port Kembla Marine Oil and Chemical Spill Contingency Plan)
Notification to the impacted community
Staff training in emergency response procedures
Assigning roles and responsibilities to key personnel
Availability of emergency response equipment
Drills, simulations – yes – once a year a live drill involving a realistic scenario is performed (e.g. power failure on spare charger car).
Environmental incident/complaint and response procedures in place, including regular discussions with Regulators
Check list of responsibilities and roles for Emergency Management Team
M MONITORING CONDITIONS
The audit assessment is based upon evidence relating to the period limited to 12 months prior to the end of the audit inspection. M6.1, M6.2 & M6.4
Yes Recording of pollution complaints
The licensee keeps a detailed record of complaints made to the licensee arising from any activity to which this licence applies and produced a sample at the request of the auditors.
M6.3 It is beyond the scope of the audit to determine whether the licensee retains the records for at least 4 years.
The licensee has records of complaints made in the past and the EPA has no reason to believe that those records would not be kept for the required 4 years.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 26 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
M7.1 Yes Operating a telephone line for receiving complaints
The licensee operates during its operating hours (24 hours per day/7days a week) a telephone line for the purpose of receiving any complaints from members of the public.
M7.2 Yes
Advertising the telephone complaints line number to the public
The licensee operates during its operating hours a telephone complaints line for the purpose of receiving any complaints from members of the public.
It was noted on the day of the audit that the site contact number was advertised at the electronic white pages (www.whitepages.com.au), and it did state that the number was an environment complaints hot line.
M7.3 This is a deeming clause that determines the applicability of Conditions M5.1-M5.2 and no assessment of compliance is required. It is noted that M5.1 and M5.2 do apply as the licence was been issued for more than 3 months.
R REPORTING CONDITIONS
The audit assessment is based upon evidence relating to the period limited to 12 months prior to the end of the audit inspection. R2.1 & R2.2 Yes
Notification of environmental harm
These requirements did apply as there were major environmental incidents causing or threatening material harm to the environment which occurred within the scope of the audit. The licensee reported over 40 incidents to the environment line in the last 12 months. A sample was taken from a range of recent incidents and these were reviewed during the audit.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
See explanation of risk assessment of non-compliances codes on p3.
FINAL/FIL11/9621/ DP 27 Environment Protection Authority
Statutory Instrument: Environment Protection Licence No. 6092
Condition No. Compliance/ Risk assessment for
non-compliance *
Comment Action required by licensee
U POLLUTION REDUCTION PROGRAMS
The audit assessment is based upon evidence relating to the period limited to 12 months prior to the end of the audit inspection. U15 (Part A) Yes
PRP 149 Coke Ovens Gas Mains Solids Management
Note: The licensee previously identified the storage of COG residues as an activity with a high environmental risk. Part A of this condition referred to the Coke Ovens Gas Mains Solids stockpiled at the premises and required a report to be submitted to the EPA by 28 February 2011.
The licensee presented EPA with a written report by the due date that:
Identified and reviewed the technically feasible options for the appropriate storage
and/or treatment and/ or disposal of the Coke Ovens gas mains solids.
Provided a cost/ benefit analysis of the feasible management options.
Nominated the preferred management option/s
Provided the expected implementation timeframe for the preferred option/s.
(The EPA requested some additional information for inclusion in the Part B report).
U15 (Part B) Not determined Part B of this condition required the preparation of a Management Plan. The licensee presented EPA with a management plan by the due date of 31 July 2011. The licensee’s report is still under review by Illawarra Office of the EPA.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
FINAL/FIL11/9621/ DP 28 Environment Protection Authority
Tank with corrosion repair and also showing spillage and/or leak residue on the compacted slag base below the site of the corrosion repair
See explanation of risk assessment of non-compliances codes on p3.
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
3.0 FURTHER OBSERVATIONS
Further observations are recorded where the audit identified issues of environmental concern which do not strictly relate to the scope of the audit or assessment of compliance. Further observations are considered to be indicators of potential non-compliances or areas where environmental performance may be improved.
Further Observation No.1 - Loss of containment of tar in the Gas Holder area, and possible migration to the Main Drain and into the harbour
During the audit inspection a floating sheen was observed on the surface of the liquid flowing in the drain adjacent to the Gas Holders and tar spatter was observed on surfaces beyond the collection pit. The licensee advised that the source of the tar was from leakages through the walls of the gas holders.
The EPA is concerned that on-site water pollution occurring as a result of the management of the gas holders and surrounding area is not being minimised as a result of the absence of adequate at-source control measures.
The EPA is also concerned that the pathway causing the escape of tar through the walls of the gas holders is also a potential pathway for the loss of containment of coke ovens and blast furnace gases from within the storages to the atmosphere. This being the case, the licensee should evaluate the gas leakage and the environmental impact.
Note: The licensee did not identify loss of containment from the gas holders as a high environmental risk, unlike the safety, plant and outrage risks.
Further Observation No.2 – Liquid (Water) discharge from areas around the BOS Furnaces (including Waste water Treatment Plant and Slag Yard) with the potential to go to Allen’s Creek.
During the audit inspection a stockpile of loose material was observed on the eastern side of Allan’s Creek Road (see photograph).
The EPA is concerned about the potential for material in the stockpile to be washed into Alan’s creek.
During the audit inspection the EPA also made two other observations where the licensee should examine opportunities to improve the control over releases of contaminated stormwater to the harbour:
(a) There appears to be transport of sediments from bare areas in stormwater from the area of the old No. 4 blast furnace to a grated field entry drain. The grate was marked to indicate that flows would enter the Port Kembla Harbour.
FINAL/FIL11/9621/ DP 30 Environment Protection Authority
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
(b) Allan’s Creek Road passes between the western end of the raw materials handling plant and a concrete barrier on the edge of the mouth of Allan’s Creek. The barrier has pipes to release stormwater to the mouth of Allan’s Creek. The accumulation of sediments around, and in these pipes increases the likelihood for the pollution of waters.
While there has been a number of PRP’s aimed at improving the quality of stormwater discharges, the EPA is concerned about the level of pollution control being installed at the sites mentioned above.
Stockpile of loose material on the side of Allan’s Creek Road, with Allan’s Creek in the background
Further Observation No.3 – Procedures, processes and equipment for managing major environmental pollution incidents
The Coke Making Department Emergency Plan (MA-CB_EME-01-01) contact telephone number for the Environment Department is shown as 6970. The purpose of this contact number is for the Coke Making Department’s emergency controller to notify the licensee’s Environment department to initiate their plan, take samples from drains and notify EPA. However the contact number provided in the Emergency Plan is incorrect. The EPA also notes that there is a backup pathway in the Emergency Response Plans for contacting the licensee’s Environment department that relies on the security contractor. The EPA has no reason to believe that the security contractors’ contacts are not being kept up to date.
The EPA is concerned that contact details in the Coke Making Department Emergency Plan is not being maintained which could result in unnecessary delays in implementing the emergency response plan.
FINAL/FIL11/9621/ DP 31 Environment Protection Authority
Compliance Audit Report BlueScope Steel (AIS) Pty Ltd
4.0 ACTION PROGRAM
The following action program must be undertaken in relation to BlueScope Steel (AIS) Pty Ltd.
Table 4.1 Action Program – Environment Protection Licence No. 6092
Condition
No. Action Details Non-Compliance
Code (where applicable)
Target/Action Date
O1.1 The licensee must implement controls and monitor the effectiveness of those controls to minimise the likelihood of discharge of stored COG main residues from the site.
Code Red 30 June 2012
EPA considers that the licensee should take the necessary actions to ensure that environmental performance is improved in relation to any matters identified as a Further Observation in Section 3.0 of this Report.
FINAL/FIL11/9621/ DP 32 Environment Protection Authority
APPENDIX A
LICENSEES RESPONSE TO DRAFT REPORT
APPENDIX B
LETTER COVERING LICENSEES RESPONSE TO DRAFT COMPLIANCE AUDIT REPORT
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