EIP4 - 2007 Environmental Action Plan

2007 ENVIRONMENTAL ACTION PLAN

This section details the environmental improvement action items that Qenos has committed to
complete in 2007. This Environmental Action Plan (EAP) has been developed in conjunction
with the Qenos Environment Monitoring Team (EMT), and has been approved by the Victorian
Environmental Protection Authority (EPA), and endorsed by the City of Hobsons Bay, City West
Water (CWW), and the local community representatives of the EMT.

Action Items
The action items are listed by Environmental Impact, as described in Section 4 of the EIP 4
framework, which follows the same format and structure as EIP 3. Several of the categories of
Environmental Impact used here are actually tools used to identify and reduce Qenos impact,
such as environmental risk assessments, auditing and training.

1.
Ref
No.
1.17

Volatile Organic Compounds (VOCs) and Oxides of Nitrogen (NOx)

Environmental
Impact
VOC & NOx

Site
Resins

Objective
Ensure accurate emissions
reporting

Plan
Update emissions calculation
processes

This item rolls over from the 2006 EAP. Most of the work has been completed, and will be
confirmed early in 2007 when the 2006 emissions data is compiled.
Qenos determines its emissions to the environment and reports on this on an annual basis. The
methodology used can vary for each material or source, ranging from direct measurement to
inferred calculation or using emission factors. It is important to Qenos that these quantities are
accurately determined to properly reflect our impact on the environment.
With the recent plant closures and the significant changes to the Scal 1 plant operation, the
calculations and methodology used needs to be thoroughly reviewed and updated to ensure it
reflects the new Qenos Altona operation, and adopts the best approach for accurate emissions
determination.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

3.

Greenhouse Gases

Ref
No.
3.5

Environmental
Impact
Greenhouse
Gases

Site
Olefins

Objective
Reduce Greenhouse Gas
emissions per unit of
production where cost
effective

Plan
Implement action items in
the GHG reduction plan for
2006

An energy efficiency study identified 19 energy reduction opportunities which have been listed
in Qenoss Greenhouse Reduction plan, required by, and approved by, the EPA. This is a three
year plan, and the listed activities must be implemented by the end of 2006. Progress has been
good with the specified 2004 and 2005 action items. The 2006 GHG reduction plan listed six
individual action items under this one EAP item number. Most were completed or closed in
2006, however one carries over into 2007.
The following item was in the plan for 2006, and the hardware required has been installed, but
still need to consolidate the operation of these new facilities in 2007.

Ref
No.
3.6

Install closed loop excess air control on Scal 2 cracking furnaces F-655/6.

Environmental
Impact
Greenhouse
Gases

Site
Plastics

Objective
Reduce Greenhouse Gas
emissions per unit of
production where cost
effective

Plan
Investigate the feasibility of
two energy efficiency
projects

This action item was originally listed in the 2005 EAP, but both projects were incomplete at
year end. Accordingly the action item was rolled over into the 2006 EAP. However, further
delays have now pushed one item out into 2007.
1. The first project to downrate the compressor gearbox was delayed due to long manufacture
time on the new gearset. Delivery is now expected early in 2007, and installation will take
place when the next opportunity presents.
2. The second project has been closed out. Hot fluff trials were completed, but QA issues
mean that this project will not be progressed.
In recognising the need to reduce energy consumption by becoming more efficient, Plastics will
investigate the feasibility of two energy efficiency projects:
1. Replacing the existing cycle gas compressors with more efficient compressors, or
modifying the existing compressor gearboxes to achieve improved efficiency.
2. Hot polyethylene powder (fluff) produced in the reactors is transferred to fluff bins where
it is stored before being transferred to the extruders where steam is used to reheat and
melt the fluff so it can be granulated. During storage in the fluff bins the temperature of
Qenos Pty Ltd
2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

the fluff decreases, so a greater amount of steam is needed to reheat and melt the fluff.
The hot fluff project will minimise the storage time in the bins by utilising the same bin
to receive fluff from the reactors and transfer it to the extruders. This will reduce the heat
loss of the fluff, hence reducing the amount of steam required for extrusion.

Ref
No.
3.11

Environmental
Impact
Greenhouse
Gases

Site
Resins

Objective
Reduce electricity
consumption

Plan
Install low wattage lighting
where appropriate

The project to upgrade the lighting at the Resins site will include the use of low wattage lighting
where appropriate, reducing the overall electricity consumption on site.

Ref
No.
3.12

Environmental
Impact
Greenhouse
Gases

Site
Resins

Objective
Reduce Greenhouse Gas
emissions per unit of
production where cost
effective

Plan
Progress Resins air
compressor rationalisation

Resins currently has five air compressors still operational. Following the closure of the
Polypropylene plant in 2005, the compressed air requirements have dropped considerably. This
project is to evaluate the optimum compressed air requirements for Polyethylene only operation,
with the aim to reduce the number of compressors in use, resulting in energy and greenhouse gas
reductions.
Some noise reduction benefits are also expected.

Ref
No.
3.13

Environmental
Impact
Greenhouse
Gases

Site
Admin

Objective
Reduce electricity
consumption

Plan
Conduct energy efficiency
audit of Main Administration
Building on the Olefins site

While electricity usage in the administration buildings is low compared to the plant equipment, a
study will be conducted to identify energy efficiency opportunities in these areas.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

7.
Ref
No.
7.5

Odour
Environmental
Impact
Odour

Site
All

Objective
Determine source of plant
odours

Plan
Conduct annual odour audit
of each site

This is an annually occurring action item, and retains the same number as for previous years.
An odour audit is conducted on each site with local community members and the EPA to identify
the main sources of odour that may have an off-site impact on the local community. Findings of
the odour audits may lead to the development of odour reduction projects.

8.
Ref
No.
8.5

Transported Wastes
Environmental
Impact
Transported
Wastes

Site
Olefins

Objective
Dispose of wastes in most
appropriate fashion

Plan
Progress the disposal of
CAA solution via suitable
method

This is a continuation of an existing Item, retaining the same number as for the 2005 and
2006 EAPs.
The BEAL unit at Olefins uses a cuprous ammonium acetate (CAA) solution to extract
butadiene. This unit has now been permanently closed as part of the Scal 1 conversion project,
and the CAA solution must be disposed of appropriately. On-site facilities for achieving this are
not presently available, so a suitable off-site disposal option must be identified.
Work done in 2005 has identified a suitable option whereby the valuable components in the CAA
solution, namely the copper and ammonia, can be recovered for re-use, leaving behind an easily
treated salt solution for disposal.
This disposal option has been progressed through 2006, but the treatment process is quite
technically difficult and it has taken longer than expected to finalise the process. Final
verification of the treatment process should be completed early in 2007, and it will then take
many months to treat all of the CAA solution.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

Ref
No.
8.10

Environmental
Impact
Transported
Wastes

Site
All

Objective
Dispose of wastes in most
appropriate fashion

Plan
Update the Waste Handling
Manual

This item carries over from the 2006 EAP. Work commenced in 2006 and continues into 2007.
The Waste Handling Manual documents each waste stream at Qenos Altona sites, including
appropriate waste disposal codes, labelling, and the preferred disposal method. Recently much of
this has been duplicated in the EPAs new WasteCert on-line electronic waste tracking system
which Qenos uses for all prescribed waste transfers.
EPA has recently released the Guidelines for Hazard Classification of Solid Prescribed Industrial
Waste, which looks ahead to improved waste treatment and the impending long term
containment facility for storage of the more hazardous material.
With the recent plant closures and Scal 1 conversion, the list of wastes at Qenos is to be reviewed
and details updated to reflect current and future requirements for waste disposal. For each waste
stream consideration will be given to current and alternative re-use, treatment and disposal
options.

Ref
No.
8.11

Environmental
Impact
Transported
Wastes

Site
All

Objective
Improve waste segregation

Plan
Implement standard general
waste bin colour

This item carries over from the 2006 EAP. Work commenced in 2006 and continues into 2007.
The scope has been broadened to include collection of recyclable materials as well as
improvements to general waste collection.
Solid waste materials at Qenos fall into three main categories:
General Waste non-hazardous, non-recyclable wastes for disposal at a municipal
landfill.
Prescribed Industrial Waste potentially hazardous waste, usually undergoing pretreatment prior to disposal at a hazardous waste landfill.
Recyclable waste waste materials that can be reused, recovered or recycled by offsite
facilities.
Segregation of these waste types is important for a number of reasons:
Prescribed waste cannot be disposed of to municipal landfills, so must not be placed in
general waste bins.
Putting general waste in with prescribed waste unnecessarily increases the amount of
material going to hazardous waste landfill, and greatly increases its disposal cost.
Contamination of recyclable materials may prevent them from being recycled.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

In order to improve waste segregation at Qenos, a standard colour (high visibility green) has been
adopted to identify general waste bins across all Altona sites, to allow easy recognition of these
bins by all site personnel and contractors. All plant based general waste bins will be painted this
new standard colour.
The roll-out of this program will include an awareness program emphasising the need for proper
segregation of waste materials in all aspects of Qenos Altona business.

Ref
No.
8.15

Environmental
Impact
Transported
Wastes

Site
Plastics
Resins

Objective
Dispose of wastes in most
appropriate fashion

Plan
Investigate recycling for
timber pallets

About 2000 timber pallets are used each year for the supply of black Masterbatch material. These
are currently being disposed of to general landfill. An alternative will be sought to establish a
recycling program for these timber pallets.

9.
Ref
No.
9.41

Water and Wastewater Management

Environmental
Impact
Water and
Wastewater

Site
Olefins

Objective

Plan

Reduce fresh water

Develop design options for
consumption and trade waste sour water re-use
volume

This sour water re-use project began in the 2006 EAP with initial project evaluation. It now
continues in 2007 to develop the action project design options, retaining the same Item
number.
At Olefins, the cracking steam condensate and other contaminated process water streams are
collected, decanted and passed through the sour water stripper (SWS), where hydrocarbons and
other contaminants are stripped out using live steam injection, to produce a stripped water stream
that is currently discharged into the sewer as waste water. This stream flowrate is typically 40-45
tonnes per hour following the Scal 1 conversion to ethane/LPG feeds, which equates to about 400
ML per year.
If the heavier hydrocarbon contaminants in this stream can be removed prior to the steam
stripping step, then the stripped sour water should be suitable for re-use as make-up water for the
Olefins cooling towers.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

Ref
No.
9.47

Environmental
Impact
Water and
Wastewater

Site
Olefins

Objective

Plan

Reduce fresh water

Evaluate demineralisation
consumption and trade waste options for boiler feed water
volume

Olefins currently uses mixed resin beds to remove dissolved salts from townwater to generate
boiler feed water. This de-ionisation process produces significant quantities of salty waste water
in the bed regeneration process, up to 70 ML per year of water.
Alternative de-ionisation technologies, such as reverse osmosis (RO), will be evaluated to
determine if it is feasible and economical to replace the existing resin beds. A new RO plant
could save up to 70 ML/year of water and reduce salt discharge to sewer by over 600 t/year.

Ref
No.
9.48

Environmental
Impact
Water and
Wastewater

Site
Olefins

Objective
Reduce fresh water
consumption

Plan
Install rainwater collection
facilities at Olefins MAB
area

Qenos plans to install a demonstration rainwater collection tank and garden watering facilities at
the Olefins Main Administration Building and Training Centre areas. The tank will be made
from Qenos polyethylene resin.

Ref
No.
9.49

Environmental
Impact
Water and
Wastewater

Site
Olefins

Objective
Improve effluent waste
water quality

Plan
Trial collection of coke in
furnace decoke sumps

During the steam cracking process in the Olefins furnaces, a layer of coke deposits on the inside
of the furnace tubes. This is burned off periodically using steam and air, with the vented steam
condensate directed into the dirty water sewer. Solid coke particles in this stream can enter the
sewer, where they will make their way down to the effluent treatment plant (ETP) where they
will settle out in the ETP sludge.
In order to reduce the volume of sludge accumulating at the ETP, it is best to catch it at the
decoke sump. It is planned to trial the use of Geotube filter bags in the decoke area to determine
if they can be used to improve coke collection and reduce the amount entering the sewer.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

Ref
No.
9.50

Environmental
Impact
Water and
Wastewater

Site
Olefins

Objective
Improve effluent waste
water quality

Plan
Reduce compressor house oil
going to sewer

Olefins has had a No Oil To Sewer (NOTS) program in place for several years now, and the
volume of oil and hydrocarbon material sent to sewer has been greatly reduced. This cleaner
production approach helps maintain trade waste discharge compliance, and also keeps the
effluent treatment plant (ETP) cleaner. However there is still a significant amount of oil reaching
the ETP where it must be removed prior to discharge to CWW sewer.
Recent investigations have shown the main source of oil going to sewer is lube oil from the
compressor house areas. Improvements will be made to better manage the oil in the compressor
house sewers to keep it from entering the dirty water sewer to the ETP.

Ref
No.
9.51

Environmental
Impact
Water and
Wastewater

Site
Plastics
Resins

Objective

Plan

Reduce fresh water

Continue developing water
consumption and trade waste reduction projects
volume

Recent projects implemented at the Polymers sites following the closure of the Resins
Polypropylene plant have seen the majority of the waste water previously discharged to CWW
sewer captured for treatment at the Plastics site and re-use as cooling tower make-up water.
The Polymers Operations Team will continue to identify and implement further water reduction
opportunities.

10.
Ref
No.
10.27

Soil and Groundwater

Environmental
Impact
Soil and
Groundwater

Site
All

Objective
Maintain EPA compliance
on groundwater

Plan
Conduct annual groundwater
monitoring

This is an annually occurring action item, and retains the same number as for previous years.
Qenos Groundwater Management Plan requires the annual sampling and testing of bore water
across the sites, and reporting of results to the EPA. This activity is usually undertaken in the 4th
quarter of each year.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

11.
Ref
No.
11.10

Flares
Environmental
Impact
Flares

Site
Olefins

Objective
Reduce flare impact on
community

Plan
Investigate automated
response for noncombustibles to flare

This item carries over from the 2006 EAP. The initial choice of technology chosen for
evaluation proved to be not suitable. Evaluation of alternative technologies continues in 2007.
During normal plant operation at Olefins, the surplus gases sent to the flares are hydrocarbons
which will readily combust at the flare tip. However, during plant equipment preparation, large
quantities of steam and nitrogen may be used to purge residual hydrocarbon material to the flare
system prior to opening for maintenance. This presents the possibility of sending a noncombustible mixture to the flares. If low levels of hydrocarbon materials are contained in this
mixture, it is possible that they may be emitted to atmosphere without being combusted and
create an odour problem downwind of the flare stacks. Such a situation occurred in October 2005
during the preparation of the Scal 1 plant for the major turnaround. Fuel gas can be manually
introduced to the flare header to ensure that the mixture is combustible. An investigation will be
conducted into the possibility of automating the response in the event that a non-combustible
mixture is sent to the flare system.

Ref
No.
11.11

Environmental
Impact
Flares

Site
Olefins

Objective
Reduce flare impact on
community

Plan
Improve flare smoke
suppression steam operation

The elevated flares at Olefins are used to safely dispose of surplus hydrocarbon gases,
particularly during plant upsets and when preparing equipment for maintenance activities. The
operation of the flares can present a potential impact on the community in a number of ways,
namely smoke due to incomplete combustion, noise from heavy flaring or smoke suppression
steam, and light from flaring at night.
In recent years, Qenos has received a number of community complaints regarding noise from the
flare operation, due mainly to suppression steam surging through poor flow control. This was
evaluated in 2006 and the local steam flow controller was found to be too basic for the advanced
control strategy required for optimum steam addition. The input signals are to be re-routed into
the plants main distributed control system (DCS) process computer, where more advanced
algorithms may be used to optimise the steam flow to the flares.

Qenos Pty Ltd

2007 Environment Action Plan

EIP4 - 2007 Environmental Action Plan

Ref
No.
11.12

Environmental
Impact
Flares

Site
Olefins

Objective
Reduce flare impact on
community

Plan
Complete a flare
management review

The 2006 mid-term accredited EPA licence audit recommended that a flare management review
be conducted to identify opportunities for improvement with the flare equipment. This will
include those issues already being addressed by action items 11.10 and 11.11 above, and may
identify further opportunities as well.
The review will be conducted by Qenos personnel, drawing on external expertise where
available, and this review will then have an independent assessment.

13.
Ref
No.
13.10

Environmental Risk Assessment

Environmental
Impact
Environmental
Risk
Assessment

Site

Objective

All

Enhance environmental risk

assessment process

Plan
Update HAZOP procedure
for abnormal operations

Hazard and Operability (HAZOPs) studies are a critical process for identifying potential risks,
including environmental impacts, from the Qenos operations. Qenos has a continual HAZOP
program, where each section of plant is re-HAZOPed on at least a 10 yearly cycle.
The 2006 mid-term accredited EPA licence audit identified that the HAZOP process did not
specifically reference abnormal or turnaround situations within the summary HAZOP procedures
to prompt consideration of these events. It was recommended that the HAZOP procedures be
updated to more clearly articulate the requirements with respect to abnormal situations, including
turnarounds and planned shutdowns.

Ref
No.
13.11

Environmental
Impact
Environmental
Risk
Assessment

Site

Objective

Olefins

Enhance environmental risk

assessment process

Plan
Improve the development
and review process for coordination procedures

Some activities at Olefins are across more than one operating unit, and may call upon a number
of separate operating procedures. In such situations a co-ordination procedure may be prepared to
highlight the various procedures and interactions involved.
The 2006 mid-term accredited EPA licence audit identified that the cumulative impact of
numerous procedures may not necessarily be addressed by the co-ordination procedure. It was
Qenos Pty Ltd
2007 Environment Action Plan

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EIP4 - 2007 Environmental Action Plan

recommended to consider initiating a review process specific to co-ordination procedures to help
identify broader cumulative impacts of key process interactions.

Ref
No.
13.12

Environmental
Impact
Environmental
Risk
Assessment

Site

Objective

All

Enhance environmental risk

assessment process

Plan
Conduct a Layers of
Protection analysis for
Environmentally Critical
equipment

To improve the risk assessment process, the 2006 mid-term accredited EPA licence audit
recommended that a critical review of all environmentally critical controls may be appropriate.
Completing a qualitative Layers of Protection analysis on each of the critical controls may
identify circumstances in which the control may not operate effectively. Typically, a Layers of
Protection analysis involves assessing the failure mechanisms of controls, while identifying a
secondary level of controls to counter the failure. In this way it assesses the adequacy of
protection layers used to mitigate a process risk.

Ref
No.
13.13

Environmental
Impact
Environmental
Risk
Assessment

Site

Objective

All

Enhance environmental risk

assessment process

Plan
Update the Environmental
Action Line log form

An Environmental Action Line is operated by Qenos Olefins on behalf of the Altona Chemical
Complex. This hotline service enables local residents to directly contact the Complex to make
enquiries or register complaints if they feel the Complex operations are impacting on the local
community. This might include noise or odour, for example.
On receiving a call, the Olefins shift team will complete an Action Line log form, and investigate
to try to ascertain the cause of the concern, and where possible cease or reduce the off-site
impact, notifying other Complex sites as required.
The 2006 mid-term accredited EPA licence audit recommended that the Action Line log form be
updated to provide useful triggers to help flesh out information from the caller to help drive the
subsequent investigation.

Qenos Pty Ltd

2007 Environment Action Plan

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EIP4 - 2007 Environmental Action Plan

Ref
No.
13.14

Environmental
Impact
Environmental
Risk
Assessment

Site

Objective

Plan

All

Enhance environmental risk

assessment process

Develop a formal response

procedure for managing
incidents with off-site impact

The 2006 mid-term accredited EPA licence audit also recommended improvements to the
procedure for investigating complaints. The aim would be to facilitate the investigation process
for rapid source identification, with key word prompts and a checklist of potential sources for the
various complaint types, namely odour and noise.

14.
Ref
No.
14.8

Training
Environmental
Impact
Training

Site
All

Objective
Train personnel in
environmental compliance

Plan
Complete Environmental
Awareness sessions for all
employees

This is an annually occurring action item, and retains the same number as for previous years.
All operations personnel, including plant operators, maintenance teams, and process support
staff, are required to attend a face to face environmental awareness session as part of the annual
training program. This session is used to inform employees of the particular environmental
impacts that Qenos can present to the local environment and what can be done to reduce these
impacts, as well as the various environmental issues Qenos may be facing through new
regulations and social expectations.
These awareness sessions also embrace sustainability principles that are applicable in the
workplace and at home.

Qenos Pty Ltd

2007 Environment Action Plan

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EIP4 - 2007 Environmental Action Plan

16.
Ref
No.
16.8

Environmental Audit and Assessments

Environmental
Impact
Environmental
Audit and
Assessments

Site
Resins

Objective
Maintain current licences

Plan
Review Resins Trade Waste
Agreement

This item was listed in the 2006 EAP, but was deferred to allow for the changes being
implemented as part of the Resins Effluent Recovery project (2006 EAP item 9.43), which
alters the nature and line-up of the Resins discharge to CWW sewer. It is expected that this
review will be conducted early in 2007.
Qenos has a Trade Waste Agreement with City West Water (CWW) for the discharge of effluent
to sewer from the Resins site. With the closure of the Polypropylene (PP) plant at Resins, the
nature of the effluent stream will change significantly, with a number of key contaminants
eliminated or greatly reduced. This agreement must be amended to reflect these changes,
including new discharge limits and the specified testing requirements.

17.
Ref
No.
17.7

Visual Appearance
Environmental
Impact
Visual
Appearance

Site
Plastics

Objective
Improve the visual
appearance

Plan
Commence HPPE plant
demolition

The High Pressure Polyethylene (HPPE) plant at the Plastics site permanently ceased operation
in 2000. Some sections of the plant have already been removed for sale. The clean-up and
demolition of the reactor and gas areas will now commence in 2007.

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