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Mason Road, Kwinana, WA 6167
Public Environmental Report
Jan 2007 Dec 2009
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TABLE OF CONTENTS
1 INTRODUCTION ..............................................................................................11
1.1 Aim and Scope of the Public Environmental Report ...............................11
1.2 General information on BP Refinery (Kwinana).......................................11
1.3 Environmental Management System .....................................................141.4 Objectives and targets............................................................................14
1.5 Major modifications since the 2006 Public Environmental Report..........15
1.6 New Significant Environmental Aspects.................................................17
2 PETROLEUM REFINING ..................................................................................18
2.1 History of BP Refinery Kwinana..............................................................18
2.2 Crude processing at BP Kwinana Refinery .............................................20
3 ENVIRONMENTAL MANAGEMENT SYSTEM...............................................293.1 Policy ......................................................................................................29
Kwinana Refinery Environmental Policy ............................................................30
3.2 Legal and other requirements.................................................................323.3 Environmental Aspects...........................................................................32
3.4 Objectives and Targets ...........................................................................32
3.5 Environmental Management Program....................................................33
3.6 Audits .....................................................................................................34
3.7 Non-conformance Reporting and Incident Investigation.........................34
3.8 Management Review .............................................................................34
4 ENVIRONMENTAL NOTIFICATIONS..............................................................35
4.1 The Structure of Environmental Enforcement ........................................35
4.2 BP Refinery (Kwinana) Environmental Notification History.....................35
5 SIGNIFICANT ENVIRONMENTAL ASPECTS .................................................37
6 AIR EMISSIONS...............................................................................................41
6.1 Introduction ............................................................................................41
6.2 Particulates.............................................................................................42
6.3 Sulphur Dioxide (SO2) .............................................................................50
6.4 Oxides of Nitrogen (NOX)........................................................................56
6.5 Carbon Dioxide (CO2)..............................................................................60
6.6 Hydrogen Sulfide (H2S) ...........................................................................72
6.7 Volatile Organic Compounds (VOC) ........................................................75
6.8 Carbon Disulphide (CS2)..........................................................................81
6.9 Odour .....................................................................................................84
6.10 Odour - Carbonyl Sulphide (COS)............................................................87
6.11 Noise ......................................................................................................906.12 Smoke ....................................................................................................94
6.13 Hydrogen fluoride (HF)............................................................................97
6.14 Methane ...............................................................................................100
6.15 Carbon Monoxide (CO) .........................................................................102
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6.16 Benzene................................................................................................108
6.17 Heavy metals........................................................................................112
6.18 1,3 Butadiene .......................................................................................122
7 WATER EMISSIONS......................................................................................125
7.1 Introduction ..........................................................................................1257.2 Waste Water Treatment Plant (WWTP)................................................127
7.3 Hydrocarbons .......................................................................................128
7.4 Sulphides..............................................................................................134
7.5 Fluoride.................................................................................................138
7.6 Phenolics ..............................................................................................142
7.7 Nitrogen................................................................................................145
7.8 Heavy metals........................................................................................150
7.9 Arsenic..................................................................................................151
7.10 Cadmium..............................................................................................154
7.11 Chromium.............................................................................................157
7.12 Cobalt ...................................................................................................160
7.13 Copper..................................................................................................163
7.14 Lead......................................................................................................166
7.15 Mercury ................................................................................................169
7.16 Nickel....................................................................................................172
7.17 Vanadium..............................................................................................175
7.18 Zinc.......................................................................................................178
7.19 pH.........................................................................................................181
7.20 Temperature.........................................................................................185
7.21 Total Suspended Solids ........................................................................188
7.22 Chemical oxygen demand (COD) / Biological oxygen demand (BOD) ..192
7.23 Refinery Water Use..............................................................................197
8 SOLID WASTE ...............................................................................................2018.1 Background...........................................................................................201
8.2 Management Systems & Waste Facilities............................................203
8.3 Current Wastes Produced & Disposal Routes......................................208
8.4 Performance.........................................................................................211
8.5 Future Plans..........................................................................................212
9 SOIL AND GROUNDWATER.........................................................................213
9.1 Historical Background...........................................................................213
9.2 Setting ..................................................................................................215
9.3 Subsurface hydrocarbon.......................................................................217
9.4 Recent Investigations...........................................................................229
9.5 LNAPL Recovery Methods ...................................................................2349.6 Subsurface product recovery................................................................238
9.7 Treatment of Contaminated Soil...........................................................240
9.8 Historical contaminated sites................................................................241
9.9 Future Plans..........................................................................................246
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10 BIODIVERSITY ...............................................................................................247
11 VERIFICATION STATEMENT ........................................................................249
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LIST OF FIGURES
Figure 1: Location of BP Refinery (Kwinana) in relation to Australia. .........................12
Figure 2: Location of BP Refinery (Kwinana) within the Kwinana Industrial
Area...................................................................................................................13
Figure 3: Location plan of BP Refinery (Kwinana). .....................................................18Figure 4: Simplified flowchart of crude processing at the BP Refinery
(Kwinana), from the Crude Distillation Units to the resulting products..............20
Figure 5: The two Crude Distillation Units at the BP Refinery (Kwinana), with
the Residue Cracking Unit in the distance. .......................................................21
Figure 6: The Catalytic Reformer (CR3) at BP Refinery (Kwinana). ............................24
Figure 7: The Bitumen Unit at BP Refinery (Kwinana). ..............................................25
Figure 8: The East flare at BP Refinery (Kwinana). ....................................................26
Figure 9: The Waste Management Area at BP Refinery (Kwinana). ..........................27
Figure 10: Salt Cooling Water Circulars .....................................................................28
Figure 11: Flow chart of the BP Refinery (Kwinana) Environmental
Management System (EMS). ............................................................................29
Figure 1: Filter elements from the Pall Filter being lifted into place...........................43Figure 13: Particulate Emissions from BP Refinery (Kwinana) from 1992 to
2009. .................................................................................................................45
Figure 14: Visible Particulate Emissions prior (left) and After the Installation
of the Pall Filter (right). ......................................................................................46
Figure 15: Hourly average particulate emissions for BP Refinery (Kwinana)
2007 and 2009 [see Note below]. .....................................................................47
Figure 16: Yearly SO2 Emissions...............................................................................54
Figure 17: Sources of NOXEmissions from BP Refinery (Kwinana) in 2009..............57
Figure 18: The NOXEmissions from the BP Refinery 1990 to 2009 (Kwinana). ........59
Figure 19: The Greenhouse Effect that creates a blanket of warm air around
the Earth. ..........................................................................................................60
Figure 20: Cogeneration Plant (COGEN) next to the Refinery that producessteam and electricity used by the Refinery.......................................................62
Figure 21: BP Kwinana Continuous Catalytic Reformer (left) and VDU furnace
(right).................................................................................................................63
Figure 22: Plantation of Maritime Pines in the South-West of Western
Australia. ...........................................................................................................64
Figure 23: Decommissioned Inefficient Boiler (left) and Mission Energys
Cogeneration Plant (right)..................................................................................65
Figure 24: New Induced Draft Fan on Crude Distillation Unit One (left) and
New Stripper Structured Packing Prior to Installation on Crude
Distillation Unit Two (right)................................................................................66
Figure 25: Energy Efficient Hydrofiner 3 Unit. ...........................................................67
Figure 26: CO2Emissions from BP Refinery (Kwinana). ............................................68
Figure 27: CO2Emissions from BP Refinery (Kwinana) (t/yr) per unit
throughput (t/yr). ...............................................................................................69
Figure 28: The Energy Intensity Index Performance at BP Refinery (Kwinana)
for the Past 8 years. The Lower the EII the Better the Performance................70
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Figure 29: Hydrogen Sulphide Emissions from BP Refinery (Kwinana). ....................74
Figure 30: Aerial View of the Tank Storage Facility at BP Refinery (Kwinana). ..........76
Figure 31: (left) The Inlet of the API (where the Oily Water Sewer Enters the
Waste Water Treatment Plant) is Open to Atmosphere, (right) Sewer
Box with Open Vent to Atmosphere. ................................................................76Figure 32: VOC Emissions (tonnes) from Different Sources Within the BP
Refinery (Kwinana) in 2009. ..............................................................................77
Figure 33: Leak Detection Monitoring at the Waste Water Treatment Plant.............78
Figure 34: Total VOC Emissions from the BP Refinery (Kwinana) since 1993...........79
Figure 35: Emissions of Carbon Disulphide from BP Refinery (Kwinana) 2007-
2009. .................................................................................................................82
Figure 35: BP Refinery (Kwinana) Land Farm cell and Waste Water
Treatment Plant (WWTP). .................................................................................85
Figure 37: COS Emissions from BP Refinery (Kwinana) 2004-2009. .........................88
Figure 38: RCU Silencer installed in 2008 at BP Refinery (Kwinana). ........................91
Figure 39: VDU Furnace.............................................................................................95
Figure 40: The new Rapid Acid Dump system, installed in 2008...............................99Figure 41: Carbon Monoxide Emissions from BP Refinery (Kwinana) from
1995 to 2009...................................................................................................104
Figure 42: Contributors of CO to the Local Airshed of Rockingham, Cockburn
and Kwinana for 2008-2009. ...........................................................................105
Figure 43: Number of Days of Unplanned Shutdown of the CO Burner at BP
Refinery (Kwinana) Compared to the Target to Achieve 98% Reliability.........106
Figure 44: Benzene Emissions by Source for 2009 from BP Refinery
(Kwinana). .......................................................................................................109
Figure 45: Benzene Emissions from BP Refinery (Kwinana)....................................110
Figure 46: Emissions of 1,3 Butadiene from BP Refinery (Kwinana). ......................123
Figure 47: Aerial photograph of the Waste Water Treatment Plant.........................126
Figure 48: Annual Average Daily Hydrocarbon Emissions to Cockburn Soundfrom BP Refinery (Kwinana) from Treated Process Wastewater. ...................130
Figure 49: Daily Hydrocarbon Emission in Process Water to Cockburn Sound........131
Figure 50: Monthly Averaged Hydrocarbon Emissions in Process Water to
Cockburn Sound..............................................................................................132
Figure 51: Quarterly Emissions of Sulphide (kg/day) to Cockburn Sound from
BP Refinery (Kwinana).....................................................................................135
Figure 52: Annual Average Daily Emissions of Sulphide from BP Refinery
(Kwinana) to Cockburn Sound. ........................................................................136
Figure 53: BP Refinery (Kwinana) Alkylation Unit. ...................................................139
Figure 54: Quarterly Average Fluoride Emissions to Cockburn Sound from BP
Refinery (Kwinana) Process Wastewater from 2007 to 2009. ........................140
Figure 55: Quarterly Average Phenol Emissions (kg/day) to Cockburn Soundfrom BP Refinery (Kwinana) Process Wastewater..........................................143
Figure 56: Nitrogen Daily Load to Cockburn Sound (kg/day) from BP Refinery
(Kwinana) Process Wastewater. .....................................................................147
Figure 57: Nitrogen Quarterly Average Emissions (kg/day) to Cockburn Sound
from BP Refinery (Kwinana) Process Wastewater..........................................147
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Figure 58: Annual Average Daily Total Nitrogen Emissions to Cockburn
Sound from BP Refinery (Kwinana) Process Wastewater...............................148
Figure 59: Monthly Average Arsenic Concentrations (mg/L) in Process
Wastewater from January 2007 July 2009...................................................152
Figure 60: Cadmium Concentrations in Wastewater from BP Refinery(Kwinana) from 2007 to 2009..........................................................................155
Figure 61: Chromium Concentrations in Wastewater from BP Refinery
(Kwinana) from 2007 to 2009..........................................................................158
Figure 62: Cobalt Concentration in Wastewater from BP Refinery (Kwinana)
from 2007 to 2009. .........................................................................................161
Figure 63: Copper Concentration in Wastewater from BP Refinery (Kwinana)
from 2007 to 2009. .........................................................................................164
Figure 64: Lead Concentration in Wastewater from BP Refinery (Kwinana)
from 2007 to 2009. .........................................................................................167
Figure 65: Mercury Concentration in Process Wastewater from BP Refinery
(Kwinana) from 2007 to 2009..........................................................................170
Figure 66: Nickel Concentration in Process Wastewater from BP Refinery(Kwinana) from 2007 to 2009..........................................................................173
Figure 67: Vanadium Concentration in Process Wastewater from BP Refinery
(Kwinana) from 2007 to 2009..........................................................................176
Figure 68: Monthly Average Zinc Concentration (mg/L) in Process
Wastewater from BP Refinery (Kwinana) from 2007 to 2009.........................179
Figure 69: pH Measurements of the Process Wastewater from BP Refinery
(Kwinana) to Cockburn Sound. ........................................................................183
Figure 70: BP Refinery (Kwinana) Salt Cooling Water flow diagram. .......................186
Figure 71: Salt Cooling Water Outfall Temperature Differences from BP
Refinery (Kwinana) 2007 to 2009. ...................................................................187
Figure 72: Monthly Average Daily Concentrations of Total Suspended Solid
(TSS) in Process Wastewater from BP Refinery (Kwinana) Dischargedto Cockburn Sound..........................................................................................190
Figure 73: The Annual Average Concentration of Total Suspended Solids
(TSS) in Process Wastewater from BP Refinery (Kwinana) Discharged
to Cockburn Sound..........................................................................................191
Figure 74: Average Monthly Concentrations of Chemical Oxygen Demand
and Biological Oxygen Demand from BP Refinery (Kwinana), 2007 to
2009. ...............................................................................................................194
Figure 75: Annual Average Concentrations of BOD (mg/L) in Process
Wastewater Discharged from BP Refinery (Kwinana).....................................195
Figure 76: Annual Average Concentrations of COD (mg/L) in Process
Wastewater Discharged from BP Refinery (Kwinana).....................................195
Figure 77: Annual Average Daily Water Use at BP Refinery (Kwinana) andWater Use Efficiency (expressed as kL water use / tonne crude
throughput). ....................................................................................................199
Figure 78: Old Landfarm (left) and the Current Waste Management Area
(right)...............................................................................................................202
Figure 79: Plan of the Waste Management Area (WMA). .......................................205
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Figure 80: (a) The Use of the Rotary Hoe to Incorporate Oily Solids into the
Landfarm for Bio-remediation (left); (b) and Spreading Oily Solids onto
the Landfarm...................................................................................................206
Figure 81: Biopile Cells at BP Refinery (Kwinana)....................................................207
Figure 82: Evidence of Subsurface Hydrocarbon Staining. ......................................214Figure 83: Photograph of NAPL (degraded diesel) Recovered from a
Groundwater Well (Courtesy of CSIRO)..........................................................218
Figure 84: BP Refinery (Kwinana) 900 Series Monitoring Bores..............................219
Figure 85: Location of the PICL and Dune Sparge Lines. ........................................223
Figure 86: Extent of LNAPL Plume..........................................................................225
Figure 87: The Dye Facility Prior to being Upgraded................................................227
Figure 88: The Dye Facility After being Upgraded. ..................................................227
Figure 89: Total Corrosion Control Yard Prior to Upgrade. .......................................228
Figure 90: Total Corrosion Control Yard After Being Upgraded. ..............................228
Figure 91: Location of PB8. .....................................................................................229
Figure 92: Benzene Concentration Contours for PB8 Investigation.........................231
Figure 93: Location of the Southern Dune Dissolved Phase Plume. .......................232Figure 94: Schematic of Passive Recovery Trench Design......................................234
Figure 95: Location of Passive Trenches at BP Refinery (Kwinana).........................235
Figure 96: Schematic and Photographs of Single Phase Skimmers. .......................236
Figure 97: Solar Powered Air Compressor Units used for Product Recovery. .........236
Figure 98: Schematic and Photographs of Dual Phase Recovery Systems. ............237
Figure 99: Photographs of VER System and Generator...........................................238
Figure 100: Historical Sub-surface Product Recovery..............................................238
Figure 101: Location of BP Refinery (Kwinana) Contaminated Sites .......................245
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LIST OF TABLES
Table 1: The Environmental Aspects for BP Refinery in 2009. ..................................38
Table 2: The standards for SO2 concentrations in the air for Western
Australia (information from DEC 2009)..............................................................52
Table 3: Emission limits (hourly averages) set by the licence issued to BPRefinery (Kwinana) to maintain SO2 concentrations set by the EPP.................53
Table 4: Performance against operational targets to control SO2 emissions. ...........54
Table 5: Assigned noise levels from the Environmental Protection (Noise)
Regulations 1997. .............................................................................................92
Table 6: Emissions of heavy metals to air from BP Refinery (Kwinana) from
2007 2009. ...................................................................................................120
Table 7: Heavy metal emissions from BP Refinery (Kwinana) as a percentage
of the total emissions of the substance to the local airshed of
Rockingham, Cockburn and Kwinana and the Perth & Rockingham
airshed in 2008-2009.......................................................................................121
Table 8: Licence Limits for Hydrocarbon Discharge from BP Refinery
(Kwinana). .......................................................................................................130Table 9: Heavy Metal yearly average load to Cockburn Sound from 2007 to
2009 from BP Refinery (Kwinana) process wastewater..................................150
Table 10: Solid Wastes at BP Refinery (Kwinana)....................................................204
Table 11: Waste Produced by BP Refinery (Kwinana) by Category
(tonnes/year). ..................................................................................................211
Table 12: Status of the Refinery Historical Contaminated Sites. .............................241
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LIST OF ABBREVIATIONS
BOD Biological Oxygen Demand
BPRK BP Refinery (Kwinana)
BTEX Benzene, toluene, ethyl benzene and xylene
CDU Crude Distillation Unit
CR3 Catalytic Reformer 3
COD Chemical Oxygen Demand
C3 Hydrocarbon consisting of 3 carbon atoms (eg propane)
C4 Hydrocarbon consisting of 4 carbon atoms (eg butane)
DEC Department of Environment and Conservation
EMS Environmental Management System
Hyd3 - Hydrofiner No.3
HSE Health, Safety and Environment
LNAPL Light Non Aqueous Phase Hydrocarbons
OWS Oily Water Sewer
ppmw parts per million by weight
RCU Residue Cracking Unit
TPH Total Petroleum Hydrocarbons
TSS Total Suspended Solids
WMA Waste Management Area
WWTP Waste Water Treatment Plant
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1 INTRODUCTION
1.1 Aim and Scope of the Public Environmental Report
As part of the BP HSE commitment to openly report our performance, good or bad,all major business operations will periodically produce a public environmental report
that is externally verified. The aim of this report is to openly report against BP
Refinery (Kwinana) significant environmental aspects.
Environmental aspects are identified by the Refinery Environmental Management
System (certified to ISO 14001:2004), and are defined as an element of an
organisations activity, product or service which can have a beneficial or adverse
impact on the environment.
This externally verified report covers the performance of the Refinery for the
Significant Environmental Aspects for the period 2007 2009. This information is
presented with a historical context where appropriate. The aspects have beengrouped into the major categories of air emissions, water emissions, soil and
groundwater. Where appropriate any Regulatory Notices or Licence exceedances
will be discussed (see section 4.1 for further definition of scope in this area).
Additional information is also provided on solid waste and biodiversity as there are no
significant environmental aspects in these areas.
It is not within the scope of this report to cover the health and safety performance of
BP Refinery (Kwinana). The scope does not include any external pipelines or BP
property leased to third parties.
1.2 General information on BP Refinery (Kwinana)
Located on the edge of the magnificent natural deep-water harbour of Cockburn
Sound, Western Australia (see Figure 1: LOaction of BP Refinery (Kwinana) in
relation to Australia), the BP Refinery (Kwinana) has been processing crude oil since
1955. The Refinery is approximately 35 km south-west of the City of Perth; the
capital city of Western Australia. The majority of the population of Western Australia
(~ 2.5 million) live within a 50 km radius of Perth. BP Refinery (Kwinana) is the only
refinery in Western Australia and one of only seven in Australia.
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Figure 1: Location of BP Refinery (Kwinana) in relation to Australia.
Currently the Refinery processes approximately 6 million tonnes of crude oil per
year. Approximately 65 percent of the Refinery products are transported by pipeline
to Fremantle and Kewdale for distribution throughout Western Australia. Theremaining 35 percent of products are exported by ship to markets in the remainder
of Australia and internationally to South East Asia, New Zealand, the South West
Pacific and Japan.
The Refinery is located in the Kwinana Industrial Area (see Figure 2: Location of BP
Refinery (Kwinana) within the Kwinana Industrial Area.) and is the most isolated
refinery in the world. Crude oil is delivered to BP Refinery (Kwinana) mostly by ship,
with a small proportion arriving via road transport.
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Figure 2: Location of BP Refinery (Kwinana) within the Kwinana Industrial Area.
The assets of the Refinery have a replacement cost of $2.5 billion, and are operatedand maintained by a permanent BP staff of 410 people who are supported by
contractors as required.
For further information on the history of the Refinery and crude processing please
refer to Section 2.
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1.3 Environmental Management System
An Environmental Management System (EMS) is a structured framework to manage
environmental issues. It is a commitment of BP Corporate for each major Business
Unit to have a certified Environmental Management System. An EMS based on ISO
14001 aims to achieve:
Compliance with legislation and regulations,
Continual improvement,
Management of significant environmental issues and
Prevention of pollution.
BP Refinery (Kwinana) first achieved certification of its EMS in 1999, was recently
recertified in January 2009 (ISO14001:2004), and will continue to undergo regular
audits to maintain this certification. For further information on the EMS at BPRefinery (Kwinana) please refer to Section 3.
1.4 Objectives and targets
The Senior Leadership Team of BP Refinery (Kwinana) set objectives and targets
every year for Significant Environmental Aspects. The objectives and targets can be
set to maintain business as usual performance, investigate, or implement an
improvement.
A single Significant Environmental Aspect can have a number of targets associated
with it, as targets can be applied to any activity or outcome. Multiple targets may be
set, for example, on the inputs that may manage a particular aspect such as
equipment reliability and availability; operational conditions such as flow and
temperature; emissions monitoring system reliability and on the outputs such as
actual emissions.
Generally targets will aim to control a particular piece of refinery equipment (and
therefore also control the performance), to achieve a task by a particular time (a likely
example is to commission a piece of equipment), or a target can directly state a limit
to the emission/occurrence of the Significant Environmental Aspect.
Targets originate from a number of sources, both internal and external. These
include; Licensing requirements, Works Approval documentation, EMS
(Environmental Management System) and BP corporate guidelines.
An example of a significant environmental aspect that has a number of targets
associated with it is particulate emissions. The Environmental Licence issued to BP
Refinery (Kwinana) by the Department of Environment and Conservation (DEC)
requires that particulate emissions from the Refinery never exceed 250 mg/m3, and
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for 95% of the time emissions must not exceed 150 mg/m3. The Refinery has set
internal targets on the air velocity in the regenerators, as this partially controls what
the particulate emissions will be, as well as targets to ensure compliance with the
licence emission limits.
The Public Environmental Report reports on the performance of the Refinery for the
period 2007 - 2009.
It is intended that a Public Environmental Report will be updated every three years
and be made available to the public via the Internet.
1.5 Major modifications since the 2006 Public Environmental Report
A number of Refinery modifications have taken place since 2006. These include the:
KWRP Tie In, SDOOL Output, Cracker Revamp, Alky RAD, Naptha Splitter,
Mercaptan Crudes, Bitumen Plant and Building Changes.
KWRP Tie In
The tie in to the Kwinana Water Reclamation Plant (KWRP) was completed in 2008.
This project involved piping high grade tertiary treated munici0ple wastewater from
KWRP into the Refinery. The KWRP purification process treats wastewater from the
Water Corporation Woodman Point treatment plant by intense microfiltration and
reverse osmosis. This water is then piped into the Refinery where it is used for
industrial processes such as steam generation and cooling.
BPs investment in the reclaimed water project has freed up nearly two GL - or 800
Olympic size swimming pools - of potable water each year for public use.
Furthermore, a future proposal to extend the use of KWRP water for firefighting and
other industrial purposes could see this increase.
SDOOL Output
The second phase of the KWRP upgrade was the connection to the Sepia
Depression Ocean Outlet Landline (SDOOL). This connection was completed in July
2009, resulting in no process wastewater being discharged into Cockburn Sound
from the Refinery. All BP process water undergoes rigorous treatment prior to
discharge. This treated wastewater is now piped through the Water Corporation
wastewater infrastructure to the Sepia Depression, 4.1 km offshore from Point
Peron. This is preferable to Cockburn Sound discharge as the Sepia Depression has
higher dilution and better assimilative capacity than the relatively poorly flushed
waters of the Sound.
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Cracker Revamp
The Residue Cracking Unit (RCU) is a key unit for the Refinery as it plays a significant
role in upgrading less valuable residue into valuable products. Furthermore products
from the RCU are processed in five other Refinery units, so availability is crucial to
the Refinery. The 2008 revamp of this unit centred on modifications to improve the
reliability, yield, process safety and reduce the environmental impacts of the RCU.
The environmental improvements achieved through the cracker revamp included: a
decrease in Refinery sound power level (a reduction in the Refinery noise impact on
the community), improvement to the storage of spent catalyst (eliminating the
potential for runoff from the storage pit to contaminate groundwater), a reduction in
particulate emissions under startup conditions and the amount of small particulates
released into the atmosphere and a reduction in Refinery water usage.
Alky RAD
HF Alkylation is one of the chemical processes required within the Refinery. Thisprocess uses a highly toxic catalyst, hydrofluoric (HF) acid. In 2007 the Alky RAD
project reduced the risk associated with this catalyst by introducing a RAD (Rapid
Acid Deinventory) system and an Emergency Shutdown System onto the Unit.
Although the project was primarily safety based there were also environmental
improvements through reduced risk of toxic spills, reduced quantities for any
potential leaks and ensuring a reduction in potential environmental impacts for such
events.
Naptha Splitter
The new naptha splitter was built in 2008 to improve feed flexibility and throughputto the Refinery octane upgrading unit, the Catalytic Reformer Three (CR3). The new
column was sized for optimal performance on any crude feedstock to ensure crude
scheduling optimisation opportunities. Furthermore, the new unit also produces
lower benzene levels in reformate.
This project had a minor environmental impact with some increases in air emissions.
These increases included: NOx (0.25%), VOC (0.01%), particulates (0.7%), CO
(0.15%), metals (0.2%), SO2(0.42%) and CO2(0.39%). The changes resulted from
improved process efficiency and a resulting increase in average feed rate. To offset
the increase in CO2, off-site carbon sinks were used. The establishment of tree
plantations on salt affected farm land in the south-west of Western Australia
mitigates the effects of land salinisation and salinisation of adjacent water bodies,and offsets the Refinery CO2 emissions. The tree plantations provide carbon
sequestration rates in the order of twenty tonnes CO2/hectare/year.
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Mercaptan Crudes
In 2008 the Mercaptan Crudes project reinstated the capability and flexibility of the
Refinery to process crude containing up to 600ppm weight mercaptan. The
improvements included reducing the volume of spent caustic generated whilst
processing mercaptan crude on the PPU1 (thus ensuring LPG product quality
[residue and sulphur] was maintained), changing the catalyst type on the Jet Merox
Unit and ensuring that there was no odour risk associated with the handling, storage
and processing of mercaptan crude. This project had predominantly economic
impacts.
Bitumen Plant
The Bitumen Emulsions plant was shut down in early 2009 resulting in a reduction in
water use for the Refinery. Furthermore, there are plans to decommission the entire
plant in the near future.
Building Changes
Between 2007 and 2009 a number of building renovations and works have been in
progress. The Central Control Building (CCB) was completed in 2008 with an
extension and blast proof cladding installed appropriate to its location within the
Refinery. The Canteen (new building) and Administration building was completed in
2008 and 2009 respectively. The Canteen is at a location further removed from the
Refinery and both have been fitted with appropriate protective materials in the
structure (ie window coverings and new roofing material (tin)). Further to this, the old
canteen building was demolished in late 2009 and a new laboratory building is in the
planning stage.
These new buildings have a number of environmental improvements includingenergy efficient lighting, water saving fixtures & fittings and infrastructure to recycle
water for garden use.
1.6 New Significant Environmental Aspects
The Refinery has identified numerous new significant environmental aspects since
the 2006 Public Environmental Report. These new aspects include numerous
category three aspects for air, category four aspects for water and new waste and
clean fuel aspects. These new additions are the result of external regulatory
obligations and the Refinerys own internal targets and objectives. The Refinery
significant environmental aspects are detailed in Section 5.
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2 PETROLEUM REFINING
2.1 History of BP Refinery Kwinana
Figure 3: Location plan of BP Refinery (Kwinana).
In the post World War Two era, Western Australia rapidly developed itsmanufacturing industries. This industry was important to enable the state to provide
for itself and create employment opportunities for a population boosted by post-war
immigration. In 1952 the Anglo-Iranian Oil Company, later to become BP, acquired
land at Kwinana, and within the same year, site preparation began with clearing and
fencing for the construction of an oil Refinery.
On the 23rd of January 1953 work officially began with the then Premier of Western
Australia, Sir Ross McLarty, turning the first soil. The first piece of Refinery
equipment was erected in September of 1953. Construction continued throughout
1954 under the direction of the American firm Kellogg, with the labour force peaking
at almost 3,500. In this year an average of three ships per week were arriving from
the United Kingdom with equipment and materials, with additional ships also arrivingfrom the eastern states of Australia.
On the 11th January 1955 the first crude oil arrived in the ship British Crusader, and
at one minute past midnight on February the 1st, crude processing began over three
months ahead of schedule.
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The Refinery at that time consisted of two Crude Distillation Units (CDU), a Vacuum
Distillation Unit (VDU), a Catalytic Reformer (CRU), Fluid Catalytic Cracker, Hydrofiner
(Hyd), Bitumen Plant and associated support equipment. At the time the Refinery
was built it was the largest industrial engineering project undertaken in Australia and
had a design capacity of three million tonnes of crude per year.
Since its original construction the Kwinana Refinery has undergone many upgrades
and additions to improve the range of crudes it can process, the range and quality of
products it can produce and improve the environmental performance of the Refinery.
Currently the Kwinana Refinery processes approximately six million tonnes of crude
per year and improvements are continuing to be made towards clean fuel
production. A simplified flow chart outlining the main processing units and products
is shown in Figure 4.
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2.2 Crude processing at BP Kwinana Refinery
BP Kwinana Refinery Flow Diagram
Crude
Distillation
Units
Amine &
Merox Unit
LPG
RecoveryPPU1
Catalytic
Reformer
Jet Merox
Sweetening
Isomerisation
Hydrofiners
Residue
Cracker
PPU2
Sulphur
Recovery
Units
CCS
Minalk
Alkylation
Cat Poly
Bitumen
Oxidiser
VacuumDistillation
Unit
Refinery Fuel Gas
Propane
Butane
Gasoline
Gasoline
Kero/Jet
Diesel
Diesel
Refinery Fuel Gas
Sulphur
Gasoline
Gasoline
Fuel Oil
Bitumen
Gas
Naphtha
Kero/Jet
Gas Oil
Atmos Residue
Figure 4: Simplified flowchart of crude processing at the BP Refinery (Kwinana), fromthe Crude Distillation Units to the resulting products.
2.2.1 Distillation
Crude oil is not one chemical compound but a combination of hydrocarbons (carbon
and hydrogen atoms bonded in various configurations) each with a unique boilingpoint. Before any other treatment crude is first distilled in the Crude Distillation Units
(CDU).
Distilling is simply a boiling process that physically separates the crude into a number
of fractions and a less volatile residue, by boiling them off at different temperatures.
There are two Crude Distillation Units, CDU1 and CDU2, which function in a very
similar way.
The crude oil is pumped from storage tanks into the CDU and heated, which
removes the lighter material from the crude oil. These lighter ends consist of
products like Liquid Petroleum Gas (LPG) that is fed to the Propane Production Unit
One (PPU1) for separation into propane and butane. The remainder of the crude is
further heated in stripping columns, which separates the side stream products
according to their different boiling temperatures. These products include kerosene
and light and heavy gas oils. The unvapourised residue (atmospheric residue) of the
crude oil that remains after the other products that have been removed forms the
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feedstock for the Vacuum Distillation Unit Two (VDU2) or the Residue Cracking Unit
(RCU). (See Figure 5).
Figure 5: The two Crude Distillation Units at the BP Refinery (Kwinana), with theResidue Cracking Unit in the distance.
2.2.2 Cracking
Residue from the Crude Distillation Units is fed into the Residue Cracking Unit (RCU)
where it is converted to lighter components that are more valuable.
The heavy residue is fed onto tiny spheres of alumina silica catalyst at high
temperatures which crack the long chain molecules of the residue. The products
from the reaction are then distilled into cracked spirit, a material suitable for blending
in motor spirit (petrol), and other components for gas oils and fuel oils.
During the process of cracking large molecules, small amounts of carbon form a
layer over the catalyst. This is referred to as coke and if left in the system it will foul
the process. The coke is removed by burning the catalyst in the regenerators, and
the catalyst can be circulated back to the reactor section of the Residue Cracking
Unit. The RCU has two regenerators, one converts the coke directly to carbon
dioxide through a combustion reaction that is supplied with excess oxygen. The
other regenerator converts the coke to carbon monoxide first by limiting the oxygen
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supply to the combustion. The CO is then converted to CO2, which is an exothermic
reaction (i.e. the reaction produces heat), and this heat is used as an energy source
to produce steam.
2.2.3 Sweetening
The term sweetening refers to the conversion of mercaptans in motor spirit into
less odorous disulphides (Leffler 2000). This is done through a series of units that
perform in slightly different ways depending on the specific product being produced,
but in this report are discussed under the same general heading.
There are two Propane Production Units, referred to as PPU1 and PPU2. The PPU1
takes overhead product from the Crude Distillation Units and removes the hydrogen
sulphide (H2S). The lighter ends then go to the Refinery fuel gas main for energy
production within the Refinery, while the bottom product goes to the Merox Section.
Here the mercaptans are extracted from the LPG and oxidised to disulphide oil, and
the remaining LPG is separated into propane and butane for sale.
The PPU2 takes LPG from the Residue Cracking Unit and removes hydrogen
sulphide and mercaptan sulphur. The mixed LPG is then split into C3 and C4
streams, which are then further treated. The C3 stream can be sold directly from this
stage, or be passed to the Catalytic Polymerisation Unit (CPU). The bulk of the C4
stream goes to the Alkylation Unit while the remainder goes to the CPU.
The CPU takes the C3 and C4 streams from the Propane Production Units and
converts them to Polygas, which is used for motor spirit blending. This is done by
diluting the feed with LPG, then heating it and passing it into a reactor. The reactor
has beds of solid phosphoric acid catalyst, and the reaction produces excess heat.
Then Polygas is separated from the C3 and C4 in the Debutaniser, after which the
Polygas can be used for blending. The C4 product generally flows to the AlkylationUnit (Butane Splitter), while the C3 product goes directly to sale.
The Hydrofiners (Hydrofiner 2 and 3) enable the Refinery to process sour crudes
(higher sulphur content). Hydrofiner Unit 2 takes Light Cycle Oil from the Residue
Cracking Unit and both take Gas Oil from the Crude Distillation Units. Sulphur is
removed through a hydrotreating process, which involves contacting the feedstock
with an alumina catalyst in the presence of hydrogen. This converts the existing
organic sulphur, nitrogen and oxygen compounds in the feed to hydrogen sulphide,
ammonia, water and hydrocarbons. The result is sweetened oil that is blended to
make diesel.
The Merox Unit takes Jet from the Crude Distillation Units and removes themercaptans. The process involves treating the Jet with a caustic soda solution in the
presence of Merox catalyst and a controlled amount of air injection. After reaction
the Jet is fed through sand and clay filters to remove traces of water and surfactants
prior to being pumped to storage.
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The Catalytic Reformer upgrades the gasoline and naphtha from the Crude
Distillation Units to make them suitable components for blending into motor spirit.
There are three parts to the Catalytic Reformer, the first section, the Naphtha
Hydrotreater (NHT) is designed to clean-up the naphtha by the removal of sulphur,
oxygen and nitrogen compounds. From this process both Light and HeavyHydrotreated Naphtha are produced, the Light Hydrotreated Naphtha is sent to the
Isomerisation unit for upgrading, while the Heavy Hydrotreated Naphtha is sent to
the next stage of the Catalytic Reformer. The Heavy Hydrotreated Naphtha is
converted to a high octane motor spirit component. This section of the Catalytic
Reformer unit is the continuous Catalyst Regenerator that regenerates the reformer
catalyst allowing the unit to run continuously.
The Isomerisation Unit uses a process designed to upgrade the octane number of
Light Hydrotreated Naphtha from the Catalytic Reformer. This conversion occurs in a
hydrogen rich atmosphere, over a fixed bed of catalyst. The reaction is exothermic,
with the heat of the products being used to preheat the incoming feed. The gas is
separated from the liquid product and the resulting Isomerate is moved to storage.
The Alkylation Unit produces high-octane motor spirit by reacting butylenes (C4) from
the Residue Cracking Unit with isobutene from the Crude Units, Catalytic Reformer
and Residue Cracking Unit. Alkylation is the reverse process of cracking, as it takes
small molecules and combines them together to make larger ones. This is done
using hydrofluoric acid (HF) as a catalyst, and produces a motor spirit component
called alkylate. The alkylate has superior stability and anti-knock qualities, therefore
when blended into aviation gasoline (Avgas) it improves the environmental and
mechanical performance. (See Figure 6).
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Figure 6: The Catalytic Reformer (CR3) at BP Refinery (Kwinana).
2.2.4 Bitumen Plant
The heavy ends of crude oil are very complex molecules with high carbon tohydrogen ratios. Bitumen is made from this substance after it is extracted in the
Vacuum Distillation Unit.
The residue from the Vacuum Distillation Unit enters the blowing tower of the
Bitumen Unit and compressed air is injected into the base of the tower. The air
causes a chemical reaction, some lighter ends are carried through the vents to the
fume disposal incinerator. Different grades/hardness of bitumen are produced by
varying the quantity of air and the temperature. (See Figure 7).
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Figure 7: The Bitumen Unit at BP Refinery (Kwinana).
2.2.5 Environmentally related units/areas
2.2.5.1 Sulphur Recovery UnitThe Refinery has two Sulphur Recovery Units that remove sulphur from gas streams
that could otherwise contribute to atmospheric emissions. The units receive H2S rich
gas from various areas of the Refinery, which is absorbed into a solvent and heated
to generate a feed gas. The H2S reacts to produce sulphur that is condensed and
stored as a hot liquid. The gas can then be used within the Refinery as an energysource and molten sulphur is sent offsite for use in the manufacture of fertilizer and
other products.
2.2.5.2 Refinery FlaresThe Refinery flare is an essential relief system that can safely dispose of any excess
gas produced by short duration surges within the Refinery process units. This
prevents the dangerous build-up of pressure, and ensures the gases are combusted
to less harmful products. (See Figure 8).
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Figure 8: The East flare at BP Refinery (Kwinana).
2.2.5.3 Waste Management AreaThe Refinery has a specifically built Waste Management Area (WMA) for thehandling, storage and treatment of solid wastes produced by the Refinery. The
handling and storage facilities in the WMA consist of a Solid Waste Shed, a Drum
shed, an Oily Waste Dewatering Shed and a Hazardous Waste shed for the separate
undercover storage of solid waste.
The WMA also has a large bunded weathering slab constructed of concrete with a
leachate collection drain and a High Density Poly-Ethylene (HDPE) liner to prevent
contamination of the underlying soil. The weathering slab is used for the mixing,
storage and weathering of solid waste.
The WMA has lined calcium fluoride dewatering pits and bunded concrete drying
slabs for the treatment of calcium fluoride prior to disposal and a landfarm facility forthe bio-remediation of oily sludges and oil contaminated soils.
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Figure 9: The Waste Management Area at BP Refinery (Kwinana).
Wastes are tracked by the Environment and Dangerous Goods Team through a
permit system controlling the movement of wastes both onsite and offsite. (See
Figure 9).
2.2.5.4 Waste Water Treatment PlantThe Waste Water Treatment Plant treats wastewater produced by the process units,
storm water runoff and maintenance work. The water flows to the plant via the Oily
Water Sewer network. The first stage of treatment is the API (American Petroleum
Institute Oil Water Separator) which uses gravity, density variation and time to
physically separate the free oil, sludge and water. The free oil is returned to the
system for reprocessing and the water is pumped to the Equalization Tank to
homogenise the flow to the remainder of the plant. From this tank the water is
treated in the Dissolved Air Flotation Unit (DAF) for removal of fine suspended oil
particles, then the dissolved phase oil and other organic contaminants (e.g.
phenolics) are removed in the Activated Sludge Units (ASU). The wastewater is
clarified and polished before disposal.
Under normal circumstances disposal of treated wastewater occurs through the
Sepia Depression Ocean Outlet Landline (SDOOL). The SDOOL is a pipeline that
ends 4km offshore at the Sepia Depression. This location has a much higher rate of
dilution than within Cockburn Sound and is subject to an extensive monitoring
program. A number of industries share the SDOOL pipeline and extensive
environmental conditions are a requirement of its use.
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The Refinery also has a once through Salt Cooling Water stream that under normal
conditions does not come into contact with hydrocarbons. This water stream is only
required to undergo primary treatment in the Salt Cooling Water oil/water separators
before the water is returned to Cockburn Sound.
Figure 10: Salt Cooling Water Circulars
See Figure 10 of the Waste Water Treatment Plant at BP Refinery (Kwinana). On the
left are two Salt Cooling Water circulars, on the right the two Activated Sludge Units
and clarifiers are visible.
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3 ENVIRONMENTAL MANAGEMENT SYSTEM
An Environmental Management System (EMS) is a structured approach to managing
environmental issues. BP Refinery (Kwinana) has an EMS based on the international
standard ISO 14001:2004, therefore the system is structured, transparent andauditable. This provides the framework for the continual improvement of
environmental performance.
BP Refinery (Kwinana) achieved its first certification of the EMS in 1999 based on
the international standard ISO 14001. The basic structure of the EMS for BP Refinery
(Kwinana) is outlined in the Figure 11 below).
1. ENVIRONMENTAL POLICY
3. OBJECTIVES AND TARGETS
4. ENVIRONMENTAL MANAGEMENT
PROGRAMME
5. AUDITING
6. NON-CONFORMANCE REPORTING
& INCIDENT INVESTIGATION
7. MANAGEMENT REVIEW
2.1. LEGAL AND OTHER REQUIREMENTS
2.2. ENVIRONMENTAL ASPECTS
4.1. .ACTION PLANS FOR TARGETS
4.2. OPERATIONAL CONTROL
(Procedures and practices)
4.3. EMERGENCY MANAGEMENT
4.4. TRAINING
4.5. ENVIRONMENTAL
RESPONSIBILITIES MATRIX
4.6. COMMUNICATION
4.7. PERFORMANCE MONITORING
4.8. RECORDS
Figure 11: Flow chart of the BP Refinery (Kwinana) Environmental ManagementSystem (EMS).
3.1 Policy
The Environmental Policy establishes the overall direction and principles of theRefinery EMS, reflecting the culture and value system of the Refinery. BP Refinery
(Kwinana) Policy is aligned with the broader HSE BP Corporate policy of no harm to
people, no accidents and no damage to the environment.
The BP Refinery (Kwinana) Environmental Policy for 2009 is shown below:
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Kwinana RefineryEnvironmental Policy
At BP Refinery Kwinana, we are committed to the BP HSE Policy and its stated
expectation of no damage to the environment. The prevention of pollution resulting
from our operations is of the highest priority to us.
We are committed not only to meeting the requirements of our Environmental
Protection Act licence and all other environmental legal obligations, but also to the
concept of best practice environmental performance. To us, this means managing
our operations to the highest standard possible to minimise our potential
environmental impact at all times.
To provide assurance both to ourselves and our community that we are managingour significant environmental issues effectively, our environmental management
system is based upon the requirements of the international standard ISO
14001:2004. It is therefore structured, transparent and auditable and provides the
framework for the continual improvement of our environmental performance.
We focus our efforts on those environmental issues which we have identified as
being most significant to the community and the receiving environment. We set
ourselves objectives and targets to manage these significant issues, which address
contributing factors within our operations as well as the emissions themselves.
All employees and contractors on our site have a role to play in our environmental
management system. We are therefore committed to training all personnel to anappropriate level to ensure the effectiveness of our environmental systems and
procedures, and to ensure an acceptable level of environmental awareness across
our site.
Our key environmental goals include:
Protecting Cockburn Sound and water resources
We protect our groundwater resources by managing our wastes effectively and by
our programmes to eliminate oil and chemical spills and improve our chemical
storage systems. We aim to eliminate oil and chemical spills from our operation and
activities. We will record and measure spills as far as possible to enable us to
prioritise our efforts in engineering out problem areas and improving procedures andpractices which may result in oil or chemical spills to the ground or water.
We aim to reduce our water consumption and manage our sewer discharges and
wastewater treatment plant operation to minimise impacts on the receiving water of
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Cockburn Sound. We will work towards zero discharge of process water to
Cockburn Sound by participating in the Kwinana Water Recycle Programme (KWRP).
Reducing greenhouse gas emissions
We participate in the Federal Government Greenhouse Challenge and set ourselvesemissions reduction and energy efficiency targets. This includes forestry trials for
carbon sequestration in salt affected areas of the State. Furthermore, we will
eliminate deliberate operation of refinery process units in a manner which causes
production of gases excess to requirements for fuel consumption, sales to Cogen, or
other sales, resulting in the disposal of the excess gases to flare. We accept the cost
penalties associated with this mode of operation.
Reducing Volatile Organic Compounds (VOC) emissions
We aim to continually reduce our VOC emissions by the use of best practice
equipment and systems and by monitoring and controlling our emissions sources.
We have programmes to install closed loop sampling systems, use environmentallyfriendly valve packings, reduce emissions from our sewers and reduce emissions
from tanks storing volatile products.
Other Atmospheric Emissions
We recognise that sulphur dioxide and nitrogen oxides have the potential to impact
on the environment, and we are therefore committed to reducing these emissions.
We will operate our plant so as to keep SO2emissions to the lowest practicable
levels and aim to reduce NOx emissions by optimising furnace performance and
efficiency and selecting low NOx burners for new furnaces and when existing
furnace burners are upgraded. We will continue to manage our particulate emissions.
Supplying Clean Fuels
We are committed to playing a role in improving Perth air quality by supplying the
cleanest possible fuels consistent with market expectations. We will continue to
work with our environmental regulator and other stakeholders to move the fuel
quality agenda forward in this state.
Des Gillen
March 2010
Business Unit Leader
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3.2 Legal and other requirements
It is a requirement of ISO 14001 to identify, and have access to, the legal and other
requirements that the Refinery believes are applicable to the environmental aspects
of its activities, products and services. The sources of these requirements include
legislation, agreements with regulators, international agreements and voluntary
commitments.
All legal and other requirements for BP Refinery (Kwinana) are compiled in the
Environmental Legal Register, and responsibilities to meet these requirements are
allocated to members of the leadership team.
3.3 Environmental Aspects
An Environmental Aspect is defined by the ISO 14001 Standard as an element of an
organizations activity, product or service which can have a beneficial or adverse
impact on the environment.
BP Refinery (Kwinana) has environmental aspects relating to air emissions, solid
wastes, wastewater discharges, soil and groundwater contamination, resource
usage (water and energy), nuisance (odour and noise), product quality and
biodiversity.
3.4 Objectives and Targets
BP Refinery (Kwinana) annually sets objectives and targets for environmental
performance based on legal and other requirements, technology options, financial,
operational and business requirements and the views of the local community and the
regulators.
All Significant Environmental Aspects have objectives and targets that reflect the
policy of the Refinery. There are three types of objectives and targets; business as
usual targets that are achieved by managing day-to-day activities, investigation
targets that are set when there is not enough information to make a change and
improvement targets that are set when a change can be implemented.
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3.5 Environmental Management Program
This is the part of the Environmental Management System that outlines how it
should be run.
3.5.1 Action Plans for targets
The Environment Management Program requires the Senior Leadership Team to
develop action plans to meet improvement and investigation targets.
3.5.2 Operational Control
Operations and activities related to significant environmental aspects have been
identified, and the engineering and operational control used to manage each
significant environmental aspect have been documented. Each of the identified
operations and activities are required to have a working procedure that sets
operating envelopes for emission control.
3.5.3 Emergency Management
All personnel must be aware of their function in an emergency situation, as set out
in the Emergency Management Plan, which provides the structure, process and
information to respond to emergencies onsite.
3.5.4 Training
The environmental training requirements for each role in the Refinery have been
determined and new appointees are required to complete their environmental
training before acting in the position.
3.5.5 Environmental Duties and Responsibilities Matrix
A duties and responsibilities matrix is maintained so the training requirements and
responsibilities for each position are recorded.
3.5.6 Communication
Internal and external communication is an important part of the Environmental
Management System. Internal reporting is required to understand the environmental
performance and successfully manage the significant environmental aspects.
External reporting provides transparency and demonstrates good citizenship.
3.5.7 Performance monitoring
The Refinery has established procedures to monitor and measure the key
characteristics of its operations and activities that may have a significant impact on
the environment.
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3.5.8 Records
The Refinery has established an Environmental Records Procedure to ensure records
are securely stored and maintained. This is done by many teams within the Refinery,
not only the Environmental Team.
3.6 Audits
An essential component of the ISO 14001 Standard for Environmental Management
System is the process of auditing. Internal audits are conducted by the Refinery to
ensure the program is working effectively and to correct any non-conformances.
Surveillance audits and re-certification audits are carried out six-monthly and three-
yearly respectively by an accredited third party organization (NATA Certification
Services International) to ensure compliance with the standard.
3.7 Non-conformance Reporting and Incident Investigation
A non-conformance occurs when a requirement of the Environmental Management
System is not fulfilled, for example failure to follow a procedure.
When an environmental incident is identified it is reported and investigated with the
actions arising from the investigation tracked to ensure adequate completion within
the nominated time frame.
The Refinery has established a procedure defining the responsibility and authority for
handling and investigating incidents. The Senior Leadership Team will determine the
level of investigation required and will appoint Investigation Team Leaders. The
recommendations resulting from the investigation will be assigned to relevant areas
and dates for completion set.
3.8 Management Review
The Annual Management Review allows the Senior Leadership Team to evaluate the
performance of the EMS and establish the EMS future direction, including the
objectives and targets for the coming year.
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4 ENVIRONMENTAL NOTIFICATIONS
4.1 The Structure of Environmental Enforcement
The enforcement guidelines of the Environmental Protection Act 1986 describe thestructure of the tiered offences and penalties regime. There are three levels of
offence under the Act reflecting the relative seriousness of offences.
Tier one offences are committed intentionally, or with criminal negligence, resulting
in actual damage to the environment or a serious breach of trust.
Tier two consists of statutory offences, such as a breach of licence condition. There
is an option to deal with a Tier two offence with a modified penalty if the Chief
Executive Officer of the DEC has the opinion it is more appropriate than a
prosecution.
Tier three offences consist of minor technical offences, and may be dealt with by an
infringement notice and the payment of a fine.
A licence exceedance is defined as exceeding a numerical threshold. Licence non-
compliance relates to any other requirements within the Licence. Please note
Licence non-compliances are only included in this document where they are
considered to have impacted on the environment.
A DEC inspector or authorized officer may also issue an Environmental Field Notice,
which is essentially a warning. Warnings may be issued in cases of minimal
potential/actual environmental damage, of a minor technical breach of instrument or
regulation, or if the matter can be quickly corrected.
4.2 BP Refinery (Kwinana) Environmental Regulatory Notices
BP Refinery (Kwinana) received two Infringement Notices and two Environmental
Field Notices between 2007 and 2009.
The first infringement notice was from the 11th November 2007 when 70L of
hydrocarbon was released from a pipeline on the Kwinana Bulk Berth #2 (formally
the AIS jetty), north of BP Refinery. This release occurred from a disused bunkerline,
not used by BP Refinery since the early 1990s. The hydrocarbon release resulted in
an oil slick of 100m by 10m in Cockburn Sound. This oil was subsequently broken up
by boat.
The DEC issued an infringement notice of $250 based on the risk being known tothe Refinery. The Refinery had attempted to access the jetty on previous occasions
to remove any remaining oil but was unable to do so due to the owner activities.
An investigation into the incident highlighted that the pipeline had been blanked
without allowing for a thermal relief valve. This resulted in a boxed in line and a
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resulting valve leak. To reduce the risk of reoccurrence the investigation ensured
internal procedural changes. These changes involved formal reviews for all activities
that modify a process or instrumentation and a review of all Kwinana Bulk Berth jetty
pipelines to assess their status and remove any residual oil.
The second infringement notice related to the discharge of firefighting foam
concentrate from the Refinery jetty on 19th October 2008. This resulted in 800L of
firefighting foam entering Cockburn Sound. This release occurred due to a hole in the
jetty foam concentrate line. The concentrate entered the water beneath the pipeline
and dissipated without foaming. The leak was stopped by relieving pressure in the
line and isolating it prior to repairs to reinstate it.
The DEC issued an infringement notice of $500 for the release of concentrate
containing zinc oxide into Cockburn Sound.
An investigation into the incident found that the pipeline had some areas of corrosion
and that the timeframe for assessment of the line was too long. To prevent such
incidents reoccurring procedural changes were implemented for improved inspectionwithin shorter timeframes and improved risk assessment and notification.
The two field notices issued between 2007 and 2009 were both related to an
inspection on the 10th July 2008;
1) in breach of Regulation 8 of the Environmental Protection (Abrasive Blasting)
Regulations 1998 for not removing abrasive blasting waste from the blasting area
as required by the Regulations (this was rectified through an update to the
appropriate procedure).
2) in breach of Regulation 10 of the Environmental Protection (Metal Coating)
Regulations 2001 for not using compliant storage for chemicals/paints (rectifiedthrough moving the chemicals/paint into the bunded, compliant storage area that
was already present and updating the procedure to ensure this becomes mandatory
within 24 hours of delivery).
BP Refinery (Kwinana) had four Licence limit exceedances and one Licence Target
exceedance during the peroid 2007 to 2009. All Licence exceedances were
attributed to Particulate emissions from the Residue Cracker Unit (RCU), these are
discussed in Section 6.2. The Licence target exceedance was attributed to Bio-
chemical Oxygen Demand (BOD) from treated process wastewater, this is
discussed further in Section 7.22.
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5 SIGNIFICANT ENVIRONMENTAL ASPECTS
An Environmental Aspect is defined by the ISO 14001 Standard as an element of an
organizations activity, product or service which can have a beneficial or adverse
impact on the environment.
The general categories of environmental aspects of BP Refinery (Kwinana) are air
emissions, solid wastes, wastewater discharges, soil and groundwater
contamination, resource usage (water and energy), nuisance (noise and odour),
product quality and biodiversity. BP Refinery (Kwinana) has developed a ranking
system that classifies each aspect in Categories One through to Four. The aspects
that qualify as a Category One are the most Significant Environmental Aspects and
are typically regulated, have a high profile and have a licence limit on emissions.
The Refinery must consider its activities, products and services, present and relevant
past activities, direct and indirect impacts, and normal, abnormal and emergency
conditions when identifying environmental aspects. Once identified, EnvironmentalAspects are assigned to a category using a number of rules specific to if it is an
air/water/soil and groundwater, solid waste or historical contaminated sites aspect.
Examples of rules that determine the category level are the licence conditions or
regulations that apply to the aspect, the potential to cause external complaints and
the potential to cause impacts on human health.
The environmental aspects for 2009 are shown in Table 1: The Environmental
Aspects for BP Refinery in 2009.
Significant Environmental Aspects have objectives and targets set for performance
each year. Some of the significant environmental aspects are also licensed by DEC.
This report compares the performance for significant environmental aspects againstlicence limits and objectives and targets where appropriate.
Some additional Environmental Aspects that are of public interest are also included
to provide a complete picture of the Refinery environmental performance, however
many of these additional Environmental Aspects do not have set formal objectives
and targets. These have been identified in Table 1: The Environmental Aspects for
BP Refinery in 2009.
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Table 1: The Environmental Aspects for BP Refinery in 2009.
AIR EMISSIONS
Category 1 Category 2 Category 3 Category 4
SOX CO Toluene H2
NOX Benzene Xylene Organic Pb
VOCs Heavy metals 1, 3 Butadiene
CO2 PAHs 1, 2 Dibromoethane
Particulates Chlorine Acetaldehyde
Odours Acid gases Cumene
Odours (COS) Dioxins Cyclohexane
H2S F Ethyl Benzene
CS2 Halons Formaldehyde
HF Ammonia n-Hexane
Smoke Phenolics
Noise Styrene
Methane
WATER EMISSIONS
Category 1 Category 2 Category 3 Category 4
Oil MBAS PAHs
Sulphides Halogenated Organics Benzene
Fluoride Chlorine/ Bromine Total Dissolved Solids
Phenols Phosphorous Toxicity
Nitrogen Dioxins Toluene
Arsenic Aluminium Xylene
Cadmium Iron Hexane
Chromium Manganese Cumene
Cobalt Selenium Styrene
Copper Ammonia Ethyl Benzene
Lead MTBE Ethylene Glycol
Nickel Cyanide
Vanadium Metals (other than those
individually listed)
Zinc
pH
Temperature
total Suspended Solids
COD/BOD
Refinery Water Use
Mercury
SOLID WASTE
Category 1 Category 2 Category 3 Category 4Alky Holding Basin Sludge Alky Cooling Tower Scrap
Wood
Alky Cooling Tower Sludge Bitumen Waste
CDU 1 Desalter Sludge Bitumen Hotmix
CDU 2 Desalter Sludge CDU Filter Salt
SGA Cooling Tower Sludge Alky Feed Drier Alumina
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Category 1 Category 2 Category 3 Category 4
Acid Tank Bottoms Air Drier Alumina
Caustic Tank Bottoms Chloride Treater
PCB Reformer Catalyst
Oily Sump SludgeReduction Gas Filter
CartridgesHX Cleaning Solids Filter Clay
Pyrophoric Scale Coalescer
Refractory Brick Coalescer Cartridges
TEL Scale Activated Alumina
CPU Catalyst Isom Catalyst
Hydrotreater Catalyst Merox Catalyst Charcoal
White Oil Tank Bottoms Merox Filter Sand
Dark Oil Tank Bottoms Activated charcoal
Slops Recovery Basin
Bottoms
PPU Molecular Sieve
WWTP Biosludge PPU Filter Sand
BPRK Contaminated Soil PPU Amine Filter Cartridge
RCU Coke
Main Fractionator Sludge
RCU Oily Catalyst
RCU/Minalk Catalyst
Air Drier Desiccant
Water tank Bottoms
Zeolite Resin
Contaminated Sulphur
SRU Amine Filter Activated
Carbon
SRU Amine Precoat Filter
Sludge
SRU Amine Storage Sludge
SRU Catalyst
Defluorinator Alumina
Calcium Fluoride
Spent Caustic Tank Bottoms
Oily WWTP Algae Scum
Polymer Sludge
Combustion Soot and Ash
Rubble - Bitumen/Concrete
Support Balls
Unit TAR Scale
Unit TAR Sludge
Garnet
Asbestos
General Waste - Non
Recycleable
General Waste RecycleableScrap Wood - General Waste
Scrap Wood - Recycleable
Pallets
Used Empty Drums
Scrap Metal - HF Service
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SOLID WASTE cont-
Category 1 Category 2 Category 3 Category 4
Scrap Metal - TEL Service
Clean Fill
Vegetation
Circular Bottom Sludge
Polishing Pond Sludge
RCU Spent E-Catalyst
RCU Catalyst Fines
CLEAN FUELS
Category 1 Category 2 Category 3 Category 4
Particulates (managed by
sulphur concentration in
diesel and petrol)
VOC (managed by RVP)
Benzene
Lead
AromaticsPhosphorous
Olefins
MTBE
SOIL AND GROUNDWATER
Category 1 Category 2 Category 3 Category 4
Sub-surface Oil Sub-surface Chemicals
BIODIVERSITY
Category 1 Category 2 Category 3 Category 4
Biodiversity
HISTORICAL CONTAMINATED SITES
Category 1 Category 2 Category 3 Category 4
Old Drum Yard Old Sand Blast Yard*
Old Scrap Metal Yard
RCU Catalyst (600s)
Old Flare Site*
Old RCU Catalyst Disposal
Area
PB8 Area
* Indicates that the site was remediated during 2007-2009
Please note the historical contaminated sites are categorised by area and not by
contaminants, this is due to the multiple analytes, above the assessment criteria.
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6 AIR EMISSIONS
6.1 Introduction
At a Petroleum Refinery atmospheric emissions primarily result from the many
combustion processes that are used in the processing of crude oils. Heaters
(furnaces), sulphur recovery units and catalytic cracking are the main point sources
of oxides of carbon, nitrogen and sulphur; and particulates. On the other hand
volatile organic compound emissions are sourced mainly from oil storage and
handling facilities, flare systems and wastewater treatment. Oil refinery processes
require a significant amount of energy; with typically more than 60% of refinery air
emissions being related to the production of energy (IPPC 2003).
The BP Refinery (Kwinana) has in place licence conditions associated withmaintaining emissions below certain thresholds as well as Continuous Emissions
Monitoring equipment reliability limits. A licence exceedance is defined as exceeding
a numerical threshold value, for example
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6.2 Particulates
6.2.1 What is it?
Particulate matter is any solid or liquid airborne substance. There are two common
size fractions for particulate matter; less that ten micrometers in diameter (PM10),and less than two and half micrometers (PM2.5). These definitions are not absolute,
as thin longer flakes or fibres may be included in either classification. Currently the
majority of attention on particulate issues is related to the PM10 size fraction
although focus on the PM2.5 size fraction has significantly increased. The values in
this report refer to total particulates which includes both size fractions.
6.2.2 Impacts
There are two issues to be considered for particulates, the impacts of the particulate
itself and the chemical composition of the particulates. The impacts of the particulate
itself on humans can include impeeding vision and irritating respiratory passages.
Emissions can also affect the aesthetics and utility of an area.
The chemical composition of the particulates can have a wider range of effects on
humans depending on their nature, ranging from toxic effects, allergic effects,
fibrosis (e.g. asbestos) or cancer. Environmental effects are also dependant on the
chemical composition as the continual addition of particulates can raise the
concentration of substances in water or soils.
6.2.3 Why do we emit it?
Particulates are produced in every combustion process. However, different fuels
produce different types and amounts of particulates. The amount can be controlled
through the conditions of combustion. As well as during combustion, particulatescan also be produced from the attrition of solid substances exposed to high wind
velocities as small pieces are broken off and carried by the air.
6.2.4 Sources
There are many na