WESTERN AUSTRALIA DEPARTMENT OF ENVIRONMENT …

WESTERN AUSTRALIA

DEPARTMENT OF ENVIRONMENT REGULATION

Environmental Protection Act 1986

AMENDED LICENCE

LICENCE NUMBER: L6107/1967/17 FILE NUMBER: 2012/004351 LICENSEE AND OCCUPIER: CSBP Limited Kwinana Beach Road KWINANA BEACH WA 6167 ACN: 008 668 371 NAME AND LOCATION OF PREMISES: CSBP Limited Part of Lot 20 on Diagram 78086, Volume 1918/Folio 244 and Part of Lot 18 on Plan 17311, Volume 2058/Folio 310 KWINANA BEACH WA 6167 (As depicted in Attachment 1)

Environmental Protection Regulations 1987 CLASSIFICATION(S) OF PREMISES: Category 31: Chemical manufacturing Category 61: Liquid waste facility Category 61A: Solid waste facility

COMMENCEMENT DATE OF LICENCE: 30 July 2011 EXPIRY DATE OF LICENCE: 29 July 2030

CONDITIONS OF LICENCE: As described and attached: DEFINITIONS GENERAL CONDITIONS GROUNDWATER PROTECTION CONDITIONS MARINE POLLUTION CONTROL CONDITIONS AIR POLLUTION CONTROL CONDITIONS Date signed: 30 June 2016 .................................................... Jonathan Bailes Manager Licensing (Process Industries) Officer delegated under Section 20 of the Environmental Protection Act 1986

Date of Issue: 14t July 2011 Date of Last Amendment: 30 June 2016

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LICENCE NUMBER: L6107/1967/17 FILE NUMBER: 2012/004351

Licence issue date: Thursday, 14 July 2011 Page 1 of 19 Date Last Amended: 30 June 2016

CONDITIONS OF LICENCE

DEFINITIONS

In these Conditions of Licence, unless inconsistent with the text or subject matter:

“annual period” means a 12 calendar month period, commencing on the 1 July;

“DER” means Department of Environment Regulation;

“CEO” for the purpose of correspondence means; Chief Executive Officer Department Administering the Environmental Protection Act 1986 Locked Bag 33 CLOISTERS SQUARE WA 6850 Email: [email protected]

“DoW” means the Department of Water;

“g/m3” means grams per cubic metre, expressed at 0 degrees Celsius and 1.0 atmosphere

pressure (101.325 kilopascals);

“g/s” means grams per second;

“kg/day” means kilograms per day;

“KWRP pipeline” means the Water Corporation operated Kwinana Water Reclamation Plant pipeline for supply of reclaimed water to industry;

“licensee” means CSBP Limited (ACN 008668371);

“licensed premises” means the operations undertaken by CSBP Limited within the premises described by the Certificate of Title as Kwinana Lots 205, 206, 208 and portion of each of Kwinana Lots 18, 207, 209 and Cockburn Sound Locations 244 and 704; the whole of the said land being Lot 20 the subject of Diagram 78086;

“m/s” means metres per second;

“MDEA” means methyl diethanolamine;

“NOx concentration” means the total combined concentration of nitric oxide and nitrogen dioxide, expressed as nitrogen dioxide, dry, at 0 degrees Celsius and 1.0 atmosphere pressure (101.325 kilopascals);

“QAP” means quality assurance program;

“reliable data” means data which meets acceptable quality criteria, verified by calibration procedures and detailed in the QAP;

“stack test” means a representative sample taken at normal operating conditions;

“start up” with reference to the integrated Ammonium Nitrate - Nitric Acid Plant means from when the reactors are 'lit-off' to when ammonia is introduced to the Selective Catalytic Reductor (SCR);

mailto:[email protected]

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“SDOOL” means the Water Corporation operated Sepia Depression Ocean Outlet Landline;

“usual business day” means Monday to Friday excluding public holidays.

Other terms take their meaning as defined in the Environmental Protection Act 1986.

GENERAL CONDITIONS

REPORTING FORMAT

G1(a) The licensee shall ensure that any continuous atmospheric discharge data submitted by the licensee in accordance with the conditions of this licence shall be computer readable and shall be:

(i) in time-series hourly-averaged listings; and

(ii) the time mark in hourly-averaged continuous data shall refer to the data collected in the hour prior to the time mark.

G1(b) The licensee shall include with submitted data all relevant targets and discharge limits associated with each substance that is required to be monitored by a condition of this licence.

G1(c) The licensee shall, for the practical purposes of reporting monitoring results, not wait for analytical results that have a long turn-around time where, in such cases, the licensee should annotate a report to the effect that certain results will be provided in the next sequential report.

ANNUAL REPORTING

G2(a) The licensee shall provide to the CEO, an annual monitoring report pursuant to:

(i) Condition G4(d) for updated information for the QAP;

(ii) Condition M3 should the emergency wastewater discharges to Cockburn Sound via the Beach outfall occur;

(iii) Condition M4(c) providing averaged wastewater data for each month in the reporting period;

(iv) Condition W1(c) for the annual groundwater monitoring report;

(v) Condition A2(a) for continuous monitoring of nitrogen oxide emissions

(vi) Condition A4(b) for a summary of hydrofluoric acid data for the Superphosphate and Granulation Plants in accordance with Condition A4(a);

(vii) Condition A5(b) for a summary of ammonia data for the Granulation Plant in accordance with Condition A4(a);

(viii) Condition A6(b) for a summary of three monthly NOx grab samples for the Ammonia Plant; and

(ix) Condition A7(b) for a summary of the stack testing data for the 2008 Ammonium Nitrate Prilling Plant.

G2(b) The licensee shall ensure that the data required by condition G2(a) for the annual period be provided to the CEO prior to 1 September of each year.

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G2(c) The Licensee shall, by 1 September each year, provide to the CEO an Annual Audit Compliance Report in the form of Attachment 3 to this licence, signed and certified in the manner required by Section C of the form indicating the extent to which the Licensee has complied with the Conditions of this licence and any previous licence issued under Part V of the Act for the premises, during the period beginning 1 July and ending on 30 June in the following year.

DISCHARGES IN EXCESS OF A TARGET OR A LIMIT

G3(a) The licensee shall notify the CEO before 5pm on the next usual business day after becoming aware that any monitoring result has exceeded a target or a limit for a waste discharge specified in any condition of this licence.

G3(b) The licensee shall provide a non-conformance report to the CEO where any monitoring results are in excess of the limits specified in any condition of this Licence within seven usual business days of that exceedance becoming known, where the exceedance report shall contain:

(i) the amount by which the limit was exceeded, supported by relevant monitoring data;

(ii) reasons for the emission levels being in excess of the limits; and

(iii) an outline of corrective action taken by the licensee to ensure that emission levels are maintained below the limits, where applicable.

G3(c) The licensee shall provide a detailed report to the CEO of the outcome of internal investigations by the licensee where any exceedance warrants further investigation, so determined by the CEO, within a time period so determined by the CEO.

QUALITY ASSURANCE PROGRAM

G4(a) The licensee shall maintain a current QAP, which describes in detail the sampling methodology, calibration, instrumentation and calculation procedures implemented to satisfy any monitoring requirement contained in the conditions of this licence. The QAP may refer to other published methods.

G4(b) The licensee shall ensure that all monitoring equipment, required by any licence condition, is calibrated in accordance with the manufacturer’s requirements or an appropriate Australian, International or appropriate standard of another country.

G4(c) The licensee shall ensure that the QAP, referred to condition G4(a), shall be amended to reflect any alterations or additions to the calibration, instrumentation and calculation procedures being adopted in practice by the licensee within three months of that change occurring.

G4(d) The licensee shall provide the CEO with an updated tabulated list of all QAPs required for accurate reporting pursuant to conditions of this licence, the condition to which they relate and the most recent revision date in each annual report.

GROUNDWATER PROTECTION CONDITIONS

GROUNDWATER MONITORING PROGRAM

W1(a) The licensee shall ensure that all water samples, required by any conditions of this licence, shall be taken, preserved, transported and analysed (where appropriate) in accordance with the latest DoW approved CSBP Ground Water Operating Strategy.

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W1(b) The licensee shall conduct groundwater monitoring in accordance with the latest DoW approved CSBP Ground Water Operating Strategy.

W1(c) The licensee shall prepare an annual groundwater monitoring report, in accordance with the requirements of condition W1(b), to indicate contours calculated from measurements and samples taken from the monitoring bores detailed in the CSBP Ground Water Operating Strategy referred to in W1(b) and shall include data required by condition W1(b).

W1(d) The licensee shall contain and recover, or absorb and dispose of, liquid resulting from spills or leaks of chemicals including fuel, oil or other hydrocarbons, whether inside or outside secondary containment compound(s).

MARINE POLLUTION CONTROL CONDITIONS

STOCKPILE MANAGEMENT

M1 The licensee shall at all time store raw materials and fertilisers (except phosphate rock) upon a sealed hardstand and under a rainproof covering.

MARINE DISCHARGES

M2(a) The licensee shall ensure that all process wastewater shall only be discharged to the environment via the:

(i) diffuser at the end of the submarine pipeline to Cockburn Sound,

(ii) SDOOL; or

(iii) emergency beach outfall to Cockburn Sound.

M2(b) The licensee shall notify the CEO of any intention to discharge wastewater other than stormwater via the emergency beach outfall to Cockburn Sound.

MONITORING PROGRAM FOR EMERGENCY MARINE DISCHARGES

M3 The licensee shall, in the event of a discharge via the beach outfall, conduct the following monitoring program in order to estimate the mass load and concentration of substances entering Cockburn Sound via the beach outfall:

(i) representative samples shall be taken of the discharge;

(ii) determine the parameters as specified in Condition M4(c); and

(iii) a record of start and stop times of wastewater discharge via the beach outfall shall be kept.

MONITORING PROGRAM FOR DISCHARGE VIA THE SUBMARINE PIPELINE OR TO SDOOL

M4(a) (i) The licensee shall collect samples from the effluent stream, that is discharged in accordance with Condition M2(a)(i) or (ii), where the samples are bulked to form a 24-hour composite sample which is representative of the effluent discharged during those 24 hours.

(ii) The licensee shall ensure that no more than ten 24-hour composite samples per year are missed due to error or malfunction.

(iii) The licensee shall ensure that no more than two consecutive 24-hour composite samples are missed.

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M4(b) The licensee shall determine the discharge of the effluent stream, as required by Condition M2(a)(i) or (ii), in cubic metres per day, on a daily basis.

M4(c) The licensee shall determine the pH and concentration of Total Inorganic Nitrogen, Orthophosphate, Aluminium, Arsenic (inorganic), Cadmium, Chromium, Cobalt, Copper, Free Cyanide, Fluoride, Iron, Lead, Manganese, MDEA, Mercury, Molybdenum, Nickel, Vanadium and Zinc, for each sample bulked on a daily basis, as required by condition M4(a). For this purpose, Total Inorganic Nitrogen is defined as the combination of ammonium ion nitrogen (NH4

+) and nitrate nitrogen

(NO3-).

DISCHARGE LIMITS

M5(a) The licensee shall ensure that the daily concentrations and monthly average daily loads of substances in effluent discharged in accordance with Condition M2 shall not exceed the limits specified in Table 1 where Total Inorganic Nitrogen, Orthophosphate, and Fluoride are calculated as a three-month rolling average.

Table 1: Discharge limits to Cockburn Sound or SDOOL

Parameter Daily concentration limit for

discharge to Cockburn

Sound /

Target concentration for

discharge to SDOOL

Monthly average daily

load limit for both the

discharge to Cockburn

Sound and SDOOL

mg/L kg/day

Total Inorganic Nitrogen - 200

Orthophosphate - 100

Arsenic (Inorganic) 0.1 -

Cadmium 0.036 -

Copper 0.285 -

Free cyanide 0.1 -

Fluoride - 54

Iron - 2.0

Manganese - 1.0

Mercury 0.0014 0.020

Molybdenum 0.25 -

MDEA 16.0 -

Zinc 2.25 -

M5(b) Effluent discharged to Cockburn Sound or to the SDOOL shall at all times be between 6.0 and 9.0 pH units except for one day in the month when the pH may be between 4.0 and 10.0.

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AIR POLLUTION CONTROL CONDITIONS

EMISSIONS MONITORING REQUIREMENTS

A1(a) The licensee shall ensure that waste gases shall only be emitted to the environment through the emission points shown in Attachment 1 and listed in Attachment 2.

A1(b) The licensee shall also report the following parameters when determining, for the purpose of any condition of this licence, the quantity and/or nature of waste gases discharged:

(i) density at stack temperature;

(ii) moisture content;

(iii) total volume flow rate at exit temperature;

(iv) exit temperature; and

(v) production rate through the relevant item of equipment from which the discharge originates, percent of maximum capacity and other notable operational circumstances likely to affect discharges from the associated item.

A1(c) The licensee shall ensure that, where any of the parameters required by Condition A1(b) are not directly measured, then estimates shall be included and declared as such, including the source and calculation method of the estimates.

A1(d) Where continuous gaseous emission analysers are required by conditions of this licence, the licensee shall ensure that reliable emissions monitoring data is obtained and recorded for:

(i) greater than 90 percent of the manufacturing plant’s stable operating time in every calendar month period; and

(ii) greater than 95 percent of the manufacturing plant’s stable operating time in any 12 consecutive calendar months.

INTEGRATED AMMONIUM NITRATE AND NITRIC ACID PLANTS

NITROGEN OXIDES MONITORING

A2(a) The licensee shall continuously monitor the emission of NOx gases from each Nitric Acid Plant.

A2(b) The licensee shall ensure that the monitoring system, required by Condition A2(a) shall measure directly or otherwise estimate the following quantities expressed as 1 hourly averages:

(i) NOx concentration g/m3; and

(ii) NOx mass emission rate in g/s.

A2(c) The licensee shall ensure that the concentration of NOx gases emitted from each Nitric Acid Plant during operation, not including the half-hour period immediately following start-up, expressed as nitrogen dioxide, shall not exceed an hourly average concentration of 0.41 g/m

3.

A2(d) The licensee shall not start-up more than one Nitric Acid Plants at the same time. A minimum of one hour shall be maintained between start-ups of the Nitric Acid Plants.

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NITROGEN OXIDES START-UP LIMITATIONS

A3(a) The licensee shall ensure that the Nitric Acid Plants shall not start-up unless a monitoring system is in place to analyse start-up NOx emissions.

A3(b) The licensee shall ensure that a record shall be kept indicating the time, prevailing wind speed and direction, and the maximum half-hourly average NOx concentration

in g/m3

, during each start-up of each Nitric Acid Plant.

A3(c) The licensee shall ensure that the NOx concentration of gases emitted from each Nitric Acid Plant during start-up, expressed as nitrogen dioxide, shall not exceed a half-hourly average concentration of 2.0 g/m

3.

SUPERPHOSPHATE MANUFACTURING AND GRANULATION PLANTS

FLUORIDE MONITORING

A4(a) The licensee shall

(i) once every calendar year take and analyse, using the relevant USEPA or other accredited method, grab samples of waste gases emitted from:

(a) the Superphosphate Manufacturing Plant scrubber stack or the Regenerative Thermal Oxidiser Stack (whichever one is being used at the time of the planned stack sampling); and

(b) the Granulation Plant scrubber stack.

(ii) at least once every three months, when the plant is operating, verify compliance of the emissions from the Superphosphate Manufacturing Plant and the Granulation Plant, through stack testing, with the targets as stated in part (c) of this condition.

A4(b) The licensee shall ensure that stack sampling, required by condition A4(a) shall

measure directly or otherwise estimate the following quantities:

(i) hydrofluoric acid concentration g/m3; and

(ii) hydrofluoric acid mass emission rate in g/s;

A4(c) The licensee shall ensure that gaseous emissions from the Superphosphate Manufacturing Plant scrubber stack, the Regenerative Thermal Oxidiser stack or the Granulation Plant scrubber stack shall not exceed the target of:

(i) 0.05 g/m3 as hydrofluoric acid; and

(ii) 2630 kilograms per month as fluoride.

GRANULATION PLANT

AMMONIA MONITORING

A5(a) The licensee shall

(i) once every calendar year take and analyse, using the relevant USEPA or other accredited method, grab samples of waste gases emitted from the Granulation Plant scrubber stacks; and

(ii) at least once every three months when the plant is operating, verify through stack testing, limits required by part (c) of this condition.

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A5(b) The licensee shall ensure that stack sampling, required by Condition A5(a) shall measure directly or otherwise estimate the following quantities:

(i) ammonia concentration g/m3; and

(ii) ammonia mass emission rate in g/s;

A5(c) The licensee shall ensure that gaseous emissions from the Granulation Plant Scrubber Stack shall not exceed 1.0 g/m

3 as ammonia.

2000 AMMONIA PLANT

MONITORING OXIDES OF NITROGEN

A6(a) The licensee shall once every three months, when the plant is operating, take grab samples of waste gases emitted from the 2000 Ammonia Plant Primary Reformer Stack and Auxiliary Boiler Stack.

A6(b) The licensee shall ensure that grab samples required by condition A6(a) shall measure directly or otherwise estimate the following quantities expressed as 1 hourly averages:

(i) NOx concentration mg/m3; and

(ii) NOx mass emission rate in g/s.

2008 AMMONIUM NITRATE PRILLING PLANT

PARTICULATES MONITORING

A7(a) The licensee shall perform at least two stack tests per year of waste gases from the 2008 ammonium nitrate prilling plant scrubber stack, where these tests are performed at least five months apart.

A7(b) The licensee shall ensure that stack testing required by condition A7(a) shall measure directly or otherwise estimate the following quantities expressed as 1 hourly averages:

(i) total particulate concentration g/m3; and

(ii) total particulate mass emission rate in g/s.

A7(c) The licensee shall ensure that total particulate emissions from the 2008 ammonium nitrate prilling plant scrubber stack, determined in accordance with condition A7(b) shall not exceed 0.05 g/m

3.

A7(d) The licensee shall ensure that stack testing required by condition A7(a) shall be conducted in accordance with USEPA method 5 or an other NATA accredited testing method.

.................................

Officer delegated under Section 20 of the Environmental Protection Act 1986 Date of Issue: Thursday, 14 July 2011 Date Last Amended: Thursday, 30 June 2016

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ATTACHMENT 1

Premises Drawings

1: Boundary of the Premises

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2: Oversight plan of the premises with five subprocesses marked

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3: Map of the Nitric Acid Plants and the location of the stacks

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4: Map of the Granulating Plant with the stacks clearly marked.

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5: Map of the Prill Plant with the stack clearly marked

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6: Map of the Super Phosphate Manufacturing Plant with the stacks marked

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7: Map of the Ammonia Manufacturing Plant

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ATTACHMENT 2

Gaseous emission points during normal operation

Emission point Emission point

abbreviation Stack height above ground level (m)

Density range (kg/m3)

Efflux velocity (m/s)

Volume

(m3/s)

Exit Temp

(oC)

Superphosphate Scrubber Stack

SMP 37.4 1.01 19.3 55

Superphosphate Regenerative Thermal Oxidiser Stack

SMP 27 136

Granulation Plant Scrubber Stack

GP 43.1 1.01 36.0 54

Granulation Plant Deduster Stack

GPDS

2008 Prilling Plant Stack PP2 65 62.7 35

Nitric Acid Plants stacks • during startup

• 100% load(1)

• 70% load(2)

NAP1, NAP2 & NAP3

64.5

0.957

0.897

0.854

27.5

17.2

26.2

19.3

60

109

128

2000 Ammonia plant Primary reformer stack CO2 recovery system Flare tower (two) Auxiliary boiler stack No.2 Tank Flare (flares gas from Tanks 1 & 2 in an emergency situation)

KAP 30 21 40 30

0.77 2.03

37

4.79

162 50

(1) operating at 100% of full load

(2) operating at 70% of full load

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ATTACHMENT 3

ANNUAL AUDIT COMPLIANCE REPORT

SECTION A

LICENCE DETAILS

Licence Number:

Licence File Number:

Company Name: Trading as:

ABN:

Reporting period: ___________________ to ___________________

STATEMENT OF COMPLIANCE WITH LICENCE CONDITIONS

1. Were all conditions of licence complied with within the reporting period? (please tick the appropriate box)

Yes □ Please proceed to Section C

No □ Please proceed to Section B

Each page must be initialed by the person(s) who signs Section C of this annual audit compliance report

INITIAL:________________

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SECTION B DETAILS OF NON-COMPLIANCE WITH LICENCE CONDITION. Please use a separate page for each licence condition that was not complied with.

a) Licence condition not complied with?

b) Date(s) when the non compliance occurred, if applicable?

c) Was this non compliance reported to DER?

Yes Reported to DER verbally Date ___________

Reported to DER in writing Date ___________

No

d) Has DER taken, or finalised any action in relation to the non compliance?

e) Summary of particulars of non compliance, and what was the environmental impact?

f) If relevant, the precise location where the non compliance occurred (attach map or diagram)

g) Cause of non compliance

h) Action taken or that will be taken to mitigate any adverse effects of the non compliance

i) Action taken or that will be taken to prevent recurrence of the non compliance

Each page must be initialed by the person(s) who signs Section C of this annual audit compliance report

INITIAL:_______________

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SECTION C SIGNATURE AND CERTIFICATION This Annual Audit Compliance Report may only be signed by a person(s) with legal authority to sign it. The ways in which the Annual Audit Compliance Report must be signed and certified, and the people who may sign the statement, are set out below. Please tick the box next to the category that describes how this Annual Audit Compliance Report is being signed. If you are uncertain about who is entitled to sign or which category to tick, please contact the licensing officer for your premises.

If the licence holder is The Annual Audit Compliance Report must be signed and certified:

an individual

□

□

by the individual licence holder, or by a person approved in writing by the Chief Executive Officer of the Department of Environment Regulation to sign on the licensee's behalf.

A firm or other unincorporated company

□

□

by the principal executive officer of the licensee; or by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

A corporation

□

□

□

□

□

□

by affixing the common seal of the licensee in accordance with the Corporations Act 2001; or by two directors of the licensee; or by a director and a company secretary of the licensee, or if the licensee is a proprietary company that has a sole director who is also the sole company secretary – by that director, or by the principal executive officer of the licensee; or by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

A public authority

(other than a local government)

□

□

by the principal executive officer of the licensee; or by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

a local government

□

□

by the chief executive officer of the licensee; or by affixing the seal of the local government.

It is an offence under section 112 of the Environmental Protection Act 1986 for a person to give information on this form that to their knowledge is false or misleading in a material particular. There is a maximum penalty of $50,000 for an individual or body corporate. I/We declare that the information in this annual audit compliance report is correct and not false or misleading in a material particular.

SIGNATURE: ______________________________

NAME:(printed) _____________________________

POSITION: _________________________________

DATE: ______/_______/________________

SIGNATURE: _____________________________

NAME: (printed) ___________________________

POSITION: _______________________________

DATE: ______/_______/________________

SEAL (if signing under seal)

Environmental Protection Act 1986 Page 1 of 23 Decision Document: L6107/1967/17 Amendment date: 30 June 2016 File Number: 2012/004351 IRLB_TI0669 v2.7

Decision Document

Environmental Protection Act 1986, Part V

Proponent: CSBP Limited

Licence: L6107/1967/17

Registered office: Kwinana Beach Road

KWINANA BEACH WA 6167 ACN: 008 668 371 Premises address: CSBP Limited

Part of Lot 20 on Diagram 78086, Volume 1918/Folio 244 and Part of Lot 18 on Plan 17311, Volume 2058/Folio 310 KWINANA BEACH WA 6167

Issue date: Thursday, 14 July 2011 Commencement date: Saturday, 30 July 2011 Expiry date: Monday, 29 July 2030 Decision Based on the assessment detailed in this document the Department of Environment Regulation (DER) has decided to issue an amended licence. DER considers that in reaching this decision, it has taken into account all relevant considerations and legal requirements and that the Licence and its conditions will ensure that an appropriate level of environmental protection is provided. Decision Document prepared by: Peter Knol

Senior Licensing Officer Decision Document authorised by: Jonathan Bailes

Delegated Officer


Contents 1 Purpose of this Document 2 2 Administrative summary 3 3 Executive summary of proposal and assessment 4 4 Decision table 5 5 Advertisement and consultation table 9 6 Risk Assessment 10 Attachment 1: Wastewater Discharges 11

1 Purpose of this Document This decision document explains how DER has assessed and determined the application and provides a record of DER’s decision-making process and how relevant factors have been taken into account. Stakeholders should note that this document is limited to DER’s assessment and decision making under Part V of the Environmental Protection Act 1986. Other approvals may be required for the proposal, and it is the proponent’s responsibility to ensure they have all relevant approvals for their Premises.


2 Administrative summary

Administrative details

Application type

Works Approval New Licence Licence amendment Works Approval amendment

Activities that cause the premises to become prescribed premises

Category number(s) Assessed design capacity

31: Chemical Manufacturing

N/A

61: Liquid waste facility N/A

61A: Solid waste facility N/A

Application verified

Application fee paid

Date: -

Date: no fee payable

Works Approval has been complied with

Compliance Certificate received

Yes No N/A

Yes No N/A

Commercial-in-confidence claim Yes No

Commercial-in-confidence claim outcome

Is the proposal a Major Resource Project? Yes No

Was the proposal referred to the Environmental Protection Authority (EPA) under Part IV of the Environmental Protection Act 1986?

Yes No

Referral decision No:

Managed under Part V

Assessed under Part IV

Is the proposal subject to Ministerial Conditions? Yes No

Ministerial statement No: 665 EPA Report No: 1135

Does the proposal involve a discharge of waste into a designated area (as defined in section 57 of the Environmental Protection Act 1986)?

Yes No

Department of Water consulted Yes No

Is the Premises within an Environmental Protection Policy (EPP) Area Yes No

Environmental Protection (Kwinana) (Atmospheric wastes) Policy 1999

Is the Premises subject to any EPP requirements? Yes No


3 Executive summary of proposal and assessment CSBP Limited (CBSP), part of the Wesfarmers Limited group, operates a large chemical manufacturing premises within the Kwinana Industrial Area, approximately 30km south of Perth. The premises consists of a number of different plants which enable a range of fertiliser and chemical products to be manufactured on site. The premises produces wastewater and collects stormwater; both are treated on site for pH correction and through the use of a large industrial wastewater wetlands system. Since 20 October 2005, CSBP has been discharging the wastewater to the Sepia Depression via the Water Corporation’s Sepia Depression Ocean Outlet Landline (SDOOL). CSBP only uses their own discharge pipe to Cockburn Sound when the SDOOL is unavailable or, in the case of extreme rainfall events, when their pumps cannot discharge the water quickly enough via the SDOOL. The industrial wastewater discharge via the SDOOL was approved by the Minister for Environment via Ministerial Statement 665. This Ministerial Statement has been amended twice following requests from Water Corporation. CSBP has requested the emission limits and targets for discharge to SDOOL be changed or removed from the licence. DER has requested advice both from the Office of the Environmental Protection Authority (OEPA) and from Water Corporation as the owner of SDOOL and as the entity responsible for the quality of the wastewater at the discharge point of SDOOL. Water Corporation replied by letter dated 29 January 2016 stating that “Water Corporation has no objection to the proposed amendments as modelling has confirmed that the proposed changes will not affect compliance with Ministerial Statement 665, nor pose a risk to the protection of the ecological or social values of the marine environment.” The OEPA responded by letter dated 21 March 2016 stating that “The Office of the Environmental Protection Authority is satisfied with DER’s and Water Corporation’s approach to managing these proposed changes.” In addition to the requested amendment to discharge limits/targets to Cockburn Sound/SDOOL, CSBP has also requested a number of minor amendments to clarify some conditions or to ensure no administrative non-compliances can occur. DER agreed with the majority of the requested amendments; these have been explained in the Decision Table.


4 Decision table All applications are assessed in line with the Environmental Protection Act 1986, the Environmental Protection Regulations 1987 and DER’s Operational Procedure on Assessing Emissions and Discharges from Prescribed Premises. Where other references have been used in making the decision, they are detailed in the decision document.

DECISION TABLE

Licence section

Condition number

Justification (including risk description & decision methodology where relevant)

Reference documents

Definitions

-- The definition of Director has been changed to CEO. This has been changed throughout the licence conditions and has not been included as changes with the individual conditions.

Marine Pollution Control Conditions

M4(a)(ii) The words “per year” have been added to this licence condition to clarify that no more than ten 24-hour composite samples can be missed per year.

M4(c) Some minor format changes have been made to this condition to make it more readable.

M5 This licence condition has been removed as CSBP has not received any hydrocarbons from BP Refinery (Kwinana) for many years, and does not expect to receive any in the foreseeable future.

M6(a) (renumbered in new licence to M5(a))

Table 3, now renamed to Table 1, has been amended as follows. 1) Column 2 (daily concentration limits/targets for 98% of the time) has been

removed; only daily concentration limit/target for 100% of the time are now specified in the licence. Limits apply to discharge to Cockburn Sound, and targets apply to discharge to SDOOL. Targets (and not limits) apply to SDOOL discharge as the increased dilution at the SDOOL (as compared to discharge to Cockburn Sound) means that when a target is breached, it does not necessarily mean a significant environmental impact has occurred. The amended limits have been reviewed by Water Corporation as the owner of the SDOOL. Water Corp have confirmed that they have “no objection to the proposed amendments as modelling has confirmed that the proposed changes

Attachment 1


DECISION TABLE

Licence section

Condition number


Reference documents

will not affect compliance with Ministerial Statement 665, nor pose a risk to the protection of the ecological or social values of the marine environment”. The OEPA have responded stating that they are satisfied with DER’s and Water Corporation’s approach. The justification for this change for each analyte is provided in Attachment 1.

2) Column 5 (target load in kg/day) has been removed; only Column 4 (monthly

average daily load limit in kg/day) is specified in the licence. A daily load limit based on monthly averaged data will provide sufficient control, and the daily target load is not required.

3) Footnotes have been removed as they contained explanatory text, are redundant, or the requirements have been clarified within the Decision Document or licence conditions.

Emission Description

Emission: Wastewater discharge via the wetlands to the Sepia Depression Ocean Outlet Landline, which discharges the combined wastewater to the Sepia Depression (about 4 km offshore).

Impact: Reduced water quality.

Controls: Wastewater is discharged within a depression in the ocean which has significant mixing ability and as such, fast dilution of the pollutants occurs. The Minister has included discharge limits on the SDOOL which Water Corporation has to comply with and which they monitor for.

Risk Assessment

Consequence: Insignificant. CSBP discharges approximately 2 Mega Litres a day (ML/day) into the SDOOL which is diluted with approximately 115 Mega Litres of treated wastewater from Woodman Point Wastewater Treatment Plant prior to discharge into the Sepia Depression where the dilution factor of 200 is achieved around the discharge point. Water Corporation is responsible for ensuring that the environmental impact on the Sepia Depression is acceptable. Water Corporation has


DECISION TABLE

Licence section

Condition number


Reference documents

modelled the proposed discharge limits and has found that the proposed changes do not pose a risk to the protection of the ecological or social values of the marine environment.

Likelihood: Unlikely. Wastewater treatment, dilution, and monitoring in place to ensure

the wastewater discharge is kept in control.

Risk Rating: Low

Regulatory Controls

The wastewater from CSBP Limited is sampled prior to discharge to the SDOOL. Daily analysis of concentrations of several pollutants is conducted to establish the average daily load. Daily average concentration limits and average daily load limits (if appropriate) are applied to several pollutants. Reporting and investigation conditions are in place for when a limit/target has been exceeded. For those substances for which limits have been removed, monitoring and reporting will continue. Residual Risk Consequence: Insignificant

Likelihood: Unlikely

Residual Risk Rating: Low

Air Pollution Control Conditions

A2(c) and A3(b) The word “average” has been added to clarify that the hourly and half hourly concentrations are averages over that period.

A4(a)(ii) The Granulation Plant experiences significant downtime during the year due to production requirements (4-6 months per year). The current condition requires stack testing every month and does not allow stack testing to be cancelled when the plant is not operational.

As such, the licence condition has been amended to read “at least once every three months, when the plant is operating, verify compliance of the emissions from the Superphosphate Manufacturing Plant and the Granulation Plant, through stack testing, with the targets as stated in part (c) of this condition.”


DECISION TABLE

Licence section

Condition number


Reference documents

A6(a) and A6(c) This condition has been amended to require three-monthly sampling instead of monthly sampling from the 2000 Ammonia Plant Primary Reformer Stack and the Auxiliary Boiler Stack. The emissions target and reporting requirement has also been removed. Justification for this is provided below:

1) The target was based on the design specification and not on the basis of environmental risk;

2) The NOx emissions from these stacks have been relatively consistent. Data from the last two annual reports show that NOx emissions range between 80 and 130 mg/m

3 confirming operation within the design specification.

3) The stacks will continue to be sampled and benchmarked against the design criteria of 144mg/m

3 NOx. These emissions are not expected to change.

A7(a) The words “take grab samples” have been removed as they were extraneous to this condition.


5 Advertisement and consultation table

Date Event Comments received/Notes How comments were taken into consideration

20/01/2016 Application referred to interested parties listed

- Office of the Environmental Protection Authority

- Water Corporation

Both interested parties responded that they accepted the proposed changes to the licence conditions.

Accepted

24/06/2016 Proponent sent a copy of draft instrument.

DER received comments from CSBP regarding:

Administrative/wording revision.

Accepted

Inclusion of footnotes in Table 1 to reference documents used in the assessment.

Footnotes have not been included in the licence as they contain explanatory text that is included in the Decision Report.

Request that an exceedance to the mercury limit/target (Table 1) would only be considered non-compliant if the amount of bioavailable and/or inorganic mercury exceeded the limit/target listed in Table 1.

Historic monitoring results have shown exceedances of the proposed mercury target to SDOOL. Exceedance of a target requires the Licensee to notify DER only (condition G3(a)). It is expected that the Licensee would investigate further to determine any environmental impact. This could include testing for bio-available mercury. Previous exceedances of the proposed target have occurred on consecutive days. Therefore, the Delegated Officer considers that it is reasonable to require the Licensee to notify target exceedances to DER so that further investigation can be carried out. On this basis, the table remains as proposed.


6 Risk Assessment Note: This matrix is taken from the DER Corporate Policy Statement No. 07 - Operational Risk Management

Table 1: Emissions Risk Matrix


Attachment 1: Wastewater Discharges CSBP has requested a review of the wastewater discharge limits and targets included in condition M6(a). To support this licence amendment request, supporting information was provided as indicated below:

“CSBP Environmental Assessment Reporting, Wastewater Discharges: August 2006 to January 2007”, Oceanica Consulting Pty Ltd, August 2007.

“Recommended Limits for Nitrogen and Orthophosphate”, Oceanica Consulting Pty Ltd, December 2007.

“Arsenic targets for Kwinana treated wastewater”, BMT Oceanica, 18 June 2014. Based on this information, CSBP has requested a change to concentration limits and target loads and limits. Water Corporation has reviewed this information and determined that the proposed changes will not pose a risk to the protection of the ecological or social values of the marine environment. The Delegated Officer has reviewed this information and determined appropriate concentration and load limits/targets. Table 2 presents the proposed changes and the Delegated Officer’s reasons for the change.


Table 2

Parameter Existing Licence Amended Licence Summary of Change

Justification

Daily concentration limit for discharge to Cockburn Sound and target for discharge to SDOOL expressed in mg/L

To stay below for 98% of time for rolling 365 days



Monthly average daily load limit for both the discharge to Cockburn Sound and SDOOL expressed in kg/day

Target load (Guideline) for both the discharge to Cockburn Sound and SDOOL expressed in kg/day

Daily concentration limit for discharge to Cockburn Sound

Target concentration for discharge to SDOOL

(To stay below for 100% of the time for rolling 365 days)

Monthly average daily load limit for both the discharge to Cockburn Sound and SDOOL

mg/L mg/L kg/day kg/day mg/L kg/day

Total Inorganic Nitrogen - - 200 750 - 200

No change to daily concentration limits.

N/A

No change to monthly average daily load limit.

N/A

Ortho-phosphate - - 100 750 - 100

No change to daily concentration limits.

N/A


N/A

Aluminium - - 1.000 0.456 - -

No change to daily concentration limits

N/A

Daily load limit has been removed.

Aluminium has not been identified as a contaminant of concern. Review of data over the last 5 years shows that the 95

th percentile for aluminium

discharged to SDOOL is 24% of the current licence limit.



Justification












Arsenic (Inorganic) 0.05 0.1 0.045 0.015 0.1 - The 98% daily concentration limit has been removed.

Only the daily concentration limit of 0.1 mg/L for 100% of the time now applies.

DER review of the supplied data indicates that arsenic concentration could be 6.2mg/L and still meet the Low-Reliability Values of the Australian and New Zealand Guidelines for Fresh and Marine Water Quality (2000). Taking a conservative approach, a value of 0.1 mg/L has been applied.

The daily load limit (kg/day) has been removed.

DER review of the supplied data indicates that loads up to 0.14 kg/day would not adversely impact the environment. Given that limits for toxicants based on loads is inconsistent with the NWQMS (due to high concentrations for short time intervals being more damaging than chronic exposure at low concentrations), the load limit has been removed. Control will be managed by the daily concentration limit.



Justification












Cadmium - - 0.137 0.008 0.036 - No daily concentration limit was previously stated in the licence. A daily concentration limit has now been included.

Monitoring data for cadmium has been consistently reported as less than the limit of reporting (i.e. 0.025 mg/L). Hence CSBP has requested that cadmium is removed from the licence. However, cadmium is identified as a contaminant of concern; a limit of 0.036mg/L is proposed due to cadmium being a bio-accumulating contaminant.

Given that the limit proposed by is relatively close to the limit of reporting, DER has included the daily concentration limit.

The daily load limit (kg/day) has been removed.

Monitoring data for cadmium has been consistently reported as less than the limit of reporting (LOR) (i.e. 0.025 mg/L). Loads have historically been calculated based on the LOR, resulting in a highly conservative assessment.

Given that limits for toxicants based on loads are inconsistent with the NWQMS, the load limit has been removed. Control will be managed by the daily concentration limit.



Justification












Chromium - 0.1 0.137 0.003 - - Daily concentration limit has been removed.

Chromium is identified as a contaminant of concern; a limit of 4.0mg/L was proposed assuming full contribution by the more toxic Cr(VI).

Monitoring data for chromium has been consistently reported as less than the limit of reporting (i.e. 0.025 mg/L).

Given that the limit of reporting is significantly less than the recommended limit, the daily concentration limit has been removed. This has been reviewed and accepted by Water Corporation.

Chromium - 0.1 0.137 0.003 - - The daily load limit (kg/day) has been removed.

Monitoring data for chromium has been consistently reported as less than the limit of reporting. Loads have historically been calculated based on the LOR, resulting in a highly conservative assessment.

Given that limits for toxicants based on loads are inconsistent with the NWQMS, the load limit has been removed.



Justification












Cobalt - 0.05 0.240 0.002 - - The daily concentration limit has been removed.

The Licensee suggests a daily concentration limit of 30 mg/L for cobalt.

Monitoring data for cobalt has been consistently reported as less than the limit of reporting (0.025mg/L).

Given the large difference between the limit of reporting and the suggested limit, the daily concentration limit has been removed. This has been reviewed and accepted by Water Corporation.

The daily load limit for cobalt has been removed.

Monitoring data for cobalt has been consistently reported as less than the limit of reporting. Loads have historically been calculated based on the LOR, resulting in a highly conservative assessment.




Justification












Copper 0.285 0.485 0.240 0.032 0.285 - Daily concentration limit (100%) of time is specified as 0.285 mg/L.

Copper is identified as a contaminant of concern; a limit of 0.6 mg/L was recommended.

Data from 2014-2015 indicated that copper concentrations are consistently below the limit of reporting (0.025 mg/L), with a few exceptions.

A limit of 0.285 mg/L (100% of the time) has been applied. This has been reviewed and accepted by Water Corporation.

The daily load limit for copper has been removed.

Monitoring data for copper has been consistently reported as less than the limit of reporting. Loads have historically been calculated based on the LOR, resulting in a highly conservative assessment.


Free cyanide - 0.1 - - 0.1 - No change. N/A

Fluoride - - 54.0 6.8 - 54 No change. N/A



Justification












Total hydrocarbon - - 5.0 5.0 - -

No change to daily concentration limit.

N/A


CSBP is no longer accepting wastewater from BP, and hence hydrocarbons are no longer required.

Iron - - 2.000 0.585 - 2.0


N/A


N/A

Lead 0.05 0.075 0.137 0.008 - - Daily concentration limit has been removed.

The Licensee suggests a daily concentration limit of 1.32 mg/L for lead.

Monitoring data for lead has been consistently reported as less than the limit of reporting (0.025mg/L).

Given the large difference between the limit of reporting and the suggested Oceanic limit, the daily concentration limit has been removed.



Justification












Lead 0.05 0.075 0.137 0.008 - - Daily load limit has been removed.

Monitoring data for lead has been consistently reported as less than the limit of reporting. Loads have historically been calculated based on the LOR, resulting in a highly conservative assessment.


Manganese - - 1 0.6 - 1


N/A

No change to daily load limit.

N/A



Justification












Mercury - - 0.020 0.002 0.0014 0.020 A daily concentration limit for mercury (0.0014 mg/L) has now been included.

Mercury is identified as a contaminant of concern; a limit of 0.0014mg/L is proposed due to mercury being a bio-accumulating contaminant.

Monitoring data for mercury has been consistently reported as less than the limit of reporting (i.e. 0.0005 mg/L). Hence CSBP has requested that mercury is removed from the licence.

However, DER review of monitoring data has shown some mercury levels approaching the proposed limit (average for March 2014 was approximately 0.001 mg/L). Therefore, the limit has been included as a conservative control.

No change made to daily load limit.

CSBP has requested that mercury is removed from the licence. However, given that a concentration limit has been included, it is appropriate that the load limit is retained for this bio-accumulating contaminant.

Molybdenum - 0.25 1.000 0.055 0.25 - No change to daily concentration limit.

N/A



Justification












Load limit has been removed.

Molybdenum is not identified as a contaminant of concern.

Monitoring results have shown values approximately 20% of the load limit.

As such the concentration limit is considered sufficient to control the risk.

MDEA - 16.0 - - - 16 No change to daily concentration limit.

N/A

No change to daily load limit.

N/A

Nickel 0.125 0.3 0.240 0.062 - - Daily concentration limit has been removed.

The Licensee suggests a daily concentration limit of 40 mg/L for nickel.

Monitoring data for nickel has been consistently reported as less than the limit of reporting (0.025mg/L).

Given the large difference between the limit of reporting and the suggested Oceanic limit, the daily concentration limit has been removed. This limit has been modelled by Water Corporation and found to be appropriate.



Justification













DER review of 2013-2015 data indicates that daily load limits for nickel have ranged from approximately 0.025kg/day to 0.05kg/day, significantly less than the current daily load limit.

Vanadium 0.050 0.06 0.137 0.006 - - Daily concentration limit has been removed.

The Licensee suggests a daily concentration limit of 32 mg/L for vanadium.

Monitoring data for vanadium has been consistently reported as less than the limit of reporting (0.025mg/L).

Given the large difference between the limit of reporting and the suggested Oceanic limit, the daily concentration limit has been removed. This limit has been modelled by Water Corp and found to be appropriate.



Justification












Load limits have been removed.

Monitoring data for vanadium has been consistently reported as less than the limit of reporting. Loads have historically been calculated based on the LOR, resulting in a conservative assessment.


Zinc - 2.25 5.0 3.0 2.25 - No change. N/A


The Licensee has recommended a concentration limit of 4.6 mg/L. DER review of monitoring data from 2013-2015 shows that concentrations have ranged from 0.025mg/L to 0.125 mg/L. Daily loads have been significantly lower than the existing load limit, no more than 0.1-0.2 kg/day.

The inclusion of the daily concentration limit of 2.25 mg/L is conservative. It is considered that the daily concentration limit is sufficient to control zinc emissions.

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