Public Environmental Review 2010-2012

Transcription

Public Environmental Report 2010-2012
BP Refinery (Kwinana) Pty Ltd
Mason Road, Kwinana, WA 6167
Table of Contents
Aim and Scope of the PER .................................................................................................... 2
BP Refinery (Kwinana)........................................................................................................... 3
The Refining Process at BP Refinery (Kwinana) .................................................................... 4
Environmental Management System .................................................................................... 5
Environmental Policy ............................................................................................................. 7
Environmental Aspects and Performance ............................................................................. 8
Air Emissions ................................................................................................................. 8
Water Emissions .......................................................................................................... 12
Soil and Groundwater................................................................................................... 17
Solid Wastes ................................................................................................................ 19
Biodiversity .................................................................................................................. 24
Water Usage ................................................................................................................ 26
Public Nuisance............................................................................................................ 28
Verification Statement......................................................................................................... 30
Contact Details.................................................................................................................... 31
Acronym Glossary .............................................................................................................. 32
Page 1 of 33
Aim and Scope of the PER
BP Refinery (Kwinana) periodically produces an externally verified Public Environmental
Report (PER) as part of the site’s commitment to openly report the company’s
environmental performance. This document aims to report the environmental aspects of the
Refinery’s operations that are of public interest and relevance. This externally verified report
covers the environmental performance of the Refinery from 2010 to 2012. The Public
Environmental Report is updated every three years and is made available to the public via
the Internet.
The process of refining crude oil characteristically has many environmental aspects and
potential environmental impacts. This document will outline all relevant environmental
aspects and any associated impacts of the Refinery’s operations. BP Refinery (Kwinana)
defines ‘relevant’ environmental aspects as those of general public interest, those which
have exceeded environmental permit limits and those which BP Refinery (Kwinana)
considers significant. The PER will explain the sources of these relevant environmental
aspects and how they are managed to minimise and prevent environmental impacts.
Page 2 of 33
BP Refinery (Kwinana)
BP Refinery (Kwinana) has
been processing crude oil since
1955 and is Australia’s largest
refinery. It is one of only six
operating refineries in Australia
and is located approximately 35
km south-west of Perth (the
capital
city
of
Western
Australia). The Refinery sits on
the edge of the natural deepwater harbour of Cockburn
Sound.
The Refinery is situated within
the Kwinana Industrial Area and
is the most isolated refinery in
the
world,
employing
approximately 450 BP staff and
400 contractors. The Refinery is
able to process many different
types of crude and produces a
broad range of transport
The location of BP Refinery (Kwinana).
fuels and
other
petroleum
products
to
stringent
environmental standards. It produces LPG, petrol, diesel, kerosene, jet fuel, avgas, Opal (a
low aromatic fuel), heating oil and Bitumen. Approximately 65 percent of the Refinery’s
products are transported by pipeline to BP terminals at Kewdale and Fremantle, and a third
party terminal, owned and operated by Coogee Chemicals Pty Ltd, for distribution
throughout Western Australia. The remaining 35 percent of products are exported by ship to
markets in the remainder of Australia, and internationally to South-east Asia. A relatively
small amount of Liquefied Petroleum Gas (LPG), bitumen and sulphur is distributed by road
transport.
Since its original construction BP Refinery (Kwinana) 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 its overall environmental performance. Currently the Refinery Nameplate
Capacity (NC) is 146 kilo barrels of crude per day.
Page 3 of 33
The Refining Process at BP Refinery (Kwinana)
Crude oil arrives at BP Refinery (Kwinana) via ship, with a small proportion arriving via road.
Prior to processing, all crude that is received by the Refinery is stored within crude storage
tanks. In this raw state crude oil is of little value to customers, therefore it must be refined
using a combination of pressure, heat and catalysts in order to convert it into useable
hydrocarbon products. The main refining processes that convert crude oil into finished
useable products are separation and conversion, with some products requiring further
purification via the removal of sulphur.
The first step in the refining process is to separate the crude oil into its naturally occurring
components. Crude oil is pumped from storage tanks into one of two Crude Distillation
Units (CDUs) where it is heated to remove the lighter material. Just as water goes from
liquid to vapour at 100°C, each type of hydrocarbon changes from liquid to vapour at its own
specific temperature range. This allows for separation through the distillation process.
Products from the distillation tower range from light gasses at the top, to very heavy
viscous liquids at the bottom. These separated products are still unfinished and require
further processing to become ‘valuable to customers’.
Although the distillation process is able to effectively separate the crude into unfinished
products, the proportions of products that exist in raw crude oil do not naturally occur in the
proportions that are demanded by consumers. In most cases there is too little petrol and too
much heavy oil. Conversion processes modify products using catalytic reactions to convert
low value heavy oil into higher value gasoline. Some products also require the removal of
sulphur. Sulphur removal produces elemental sulphur and water. The sulphur is sold as
feedstock for other industries.
Finished products leave the Refinery via pipeline, trucks or ships to be sold to consumers.
BP Refinery (Kwinana) ensures all products that leave the Refinery meet quality
specifications under the federal Fuel Quality Standards Act 2000 and environmental
standards under the State’s Environmental Protection (Petrol) regulations 1999. This
ensures that clean fuels are supplied to consumers.
Diagram showing crude processing at BP Refinery (Kwinana).
Page 4 of 33
Environmental Management System
It is a commitment of BP Corporate that all of BP’s operating sites have a certified EMS
based on the ISO 14001:2004 standards. Under these international standards the Refinery’s
EMS aims to achieve:

Compliance with legislation and regulations,

Continual improvement,

Management of significant environmental issues and

Prevention of pollution.
The purpose of the EMS is to provide a structured transparent and auditable framework to
manage environmental issues.
BP Refinery (Kwinana) first achieved ISO14001:2004 certification of its EMS in 1999, and
was most recently recertified in January 2012. The Refinery will continue to undergo regular
and comprehensive audits to maintain this certification. Regular audits help to identify the
strengths and improvement opportunities in the operation of the Refinery’s EMS. Therefore,
the Refinery’s EMS is a continual improvement process of planning, implementing,
checking and reviewing.
The continual improvement process of the Refinery’s EMS.
Page 5 of 33
The Refinery’s ISO 14001 EMS Certification.
Page 6 of 33
Environmental Policy
Page 7 of 33
Environmental Aspects and Performance
An environmental aspect is an element of an organisation’s activities, products or services
that can interact with the environment. An environmental aspect has the potential to have
an environmental impact, which is any change to the environment, whether adverse or
beneficial, that results from an organisation’s operation.
The general categories of environmental aspects at BP Refinery (Kwinana) are:







Air emissions
Water emissions
Soil and groundwater contamination
Solid waste disposal
Biodiversity
Water usage and
Public nuisance (noise and odour)
Air Emissions
Air emissions are one of the Refinery’s most significant environmental aspects. At all oil
refineries a level of air emissions is an inevitable result of the combustion processes that
are required to refine crude oil. Emissions to the air from the refining process have the
potential to contribute to local and global environmental impacts if not managed adequately.
Management of air emissions at the Refinery involves a combination of emission monitoring
techniques and on-going design reviews to ensure that the processes and equipment used
onsite help to minimise the Refinery’s air emissions.
Sulphur Oxides (SOx)
SOx are released by the burning of fuels
containing sulphur. They are emitted from
the Refinery from several sources, with the
main ones being the Residue Cracking Unit
(RCU) and the Sulphur Recovery Units
(SRUs).
SOx (tonnes/yr)
Management of Air Emissions
5000
4500
4000
3500
3000
2500
2000
1500
1000
500
0
Historical Average 2004-9
SOx emissions are managed in a number of
ways at BP Refinery (Kwinana). Firstly, the
Refinery uses natural gas to feed its
2010
2011
2012
furnaces as a supplement to fuel containing
sulphur in order to reduce SOx emissions. Annual SO emissions from BP Refinery
x
The Refinery also uses two SRUs which are
(Kwinana).
part of the system used to remove sulphur
from the Refinery’s products and convert it to pure sulphur. The recovered sulphur is then
Page 8 of 33
recycled and used in the manufacture of fertilisers by other companies. SOx emissions are
constantly monitored by Continuous Emissions Monitors (CEMs) on both of the SRUs and
the RCU. These provide live monitoring of emissions and help to aid in the daily
management of feedstock and process conditions. The management of feedstock involves
the selection of sweet or sour crudes (low sulphur content or high sulphur content) and the
subsequent configuration of the refining process to suit the type of crude being processed
(for example a crude with high sulphur will require additional sulphur removal).
Environmental performance for SOx emissions was consistent with historical levels in 2010
and 2012. The increase in 2011 was due to the processing of crude with high sulphur
content.
900
800
NOx (tonnes/yr)
Nitrogen Oxides (NOx)
NOx are formed from the nitrogen and fuel
in air during combustion processes. They
are mainly emitted through the Refinery’s
furnace stacks. In comparison to the volume
of NOx emissions released by motor
vehicles in urban areas, BP Refinery
Kwinana and similar industries are a
comparatively minor source.
700
600
500
400
300
200
100
The Refinery works to minimise NOx
0
emissions by using natural gas to
2010
2011
2012
supplement furnace fuel as it contains a
lower concentration of nitrogen. Where Annual NO emissions from BP Refinery
x
appropriate the Refinery selects low NOx (Kwinana).
burners in the sites furnaces. The Refinery’s
Continuous Catalytic Reformer is one example of a unit that was built with all low NOx
burners in order to reduce emissions. NOx emissions from those units which still have
traditional furnaces are managed by maintaining optimal levels of excess oxygen in the flue
gas. Excess oxygen helps to keep temperature low so that less of the nitrogen in the air is
converted to NOx. Environmental performance for NOx emissions was consistent with
historical levels.
Carbon Dioxide (CO2)
CO2 contributes to a group of gases referred to as ‘Green House Gases’. At the Refinery, it
is formed by the combustion of materials containing carbon.
CO2 emissions from BP Refinery (Kwinana) are linked to the sites energy consumption. The
Refinery has an ‘Energy Strategy’ that monitors and implements projects to improve the
sites energy efficiency. One project that has been implemented as part of the Energy
Strategy is the ‘no economic flaring’ policy. This policy requires the Refinery to only operate
to the level at which it can use all fuel gas produced. Other, indirect emissions are managed
through projects which aim to reduce energy use and improve energy efficiency.
Page 9 of 33
800000
700000
CO2 (tonnes/yr)
The Refinery also offsets its carbon
emissions though Pine Tree plantations in
the Southwest of Western Australia. The
trees act as a carbon ‘sink’, allowing for the
sequestration of CO2. In addition, to
offsetting CO2 emissions the tree
plantation is helping to deal with salinity
problems in the south-west of Western
Australia. The planting of deep rooted trees
helps to lower the water table and reduce
the seepage of saline waters to the soil
surface. Environmental performance for
CO2 emissions was consistent with
historical levels.
600000
500000
400000
300000
200000
100000
0
2010
2011
2012
Annual CO2 emissions from BP Refinery
(Kwinana).
Volatile Organic Compounds (VOC’s)
VOC’s are comprised of a variety of compounds that vaporise at ambient temperature and
pressure. They are emitted from the Refinery’s storage tanks, the sewer systems, process
units and leaking valves/flanges.
Fugitive VOC emissions are managed by
the site’s Leak Detection and Repair
1800
Program, where fugitive VOC leaks are
1750
systematically
detected
and
leaking
equipment repaired or replaced. The
1700
Refinery also has a program in place which
1650
ensures that all new valves use
environmentally friendly ‘valve packing’
1600
(have low leak potential). VOC emissions in
1550
2010 were significantly higher than
2010
2011
2012
historical levels. This increase was due to
the waste heat recovery boiler in the RCU
Annual VOC emissions from BP Refinery
(Kwinana).
being offline for an extended period of time.
Additionally, a new VOC emission source
was introduced to the calculation in 2010 which accounts for approximately 20% of the
observed increase.
VOCs (tonnes/yr)
1850
Page 10 of 33
Particulate Matter (PM)
PM is small airborne particles. The major source of particulate emissions at BP Refinery
(Kwinana) is the RCU.
Particulate Matter <10µm
(tonnes/yr)
PM emissions from the RCU are managed
through the use of cyclones and a filtration
140
system. Additionally, In 2012 BP Refinery
120
Kwinana had a major Turn Around event (TAR)
100
during which maintenance was conducted and
80
improvements were made to the RCU to help
to reduce future PM emissions. Two
60
improvements were made, the first being the
40
replacement of the Polutrol cyclone to
20
improve performance. The second, the
0
procurement of a spare Pall filter element. In
2010
2011
2012
the past PM emissions have increased during
the maintenance and cleaning of the Pall filter
Annual PM10 emissions from BP Refinery
element. This increase in PM emissions can
(Kwinana).
now be minimised as the two Pall filter
elements can simply be rotated out resulting in significantly less filter downtime.
Environmental performance for particulate matter has improved from historical levels.
Overall Environmental Performance for Air Emissions
The drop observed for all emissions in 2012 is in part attributed to a reduction in crude
processing during the 2012 TAR, which is a Refinery maintenance/shutdown event.
BP Refinery (Kwinana) had five environmental permit violations related to particulate
emissions during the 2010 to 2012 period. There was one permit violation in 2010, one in
2011 and three in 2012. The violations were related to the start-up of the CO Burner and
RCU and equipment malfunction. There was one environmental permit violation for SOx,
during the 2010 to 2012 period. Total Refinery SO2 exceeded the environmental permit
limit in May 2010. This exceedance was attributed to an unexpected power outage. All
environmental permit exceedances are investigated and corrective actions are put in place
to reduce the probability of a reoccurrence.
Page 11 of 33
Water Emissions
One of the by-products of the refining process at BP Refinery (Kwinana) is water. The
Refinery discharges two types of water, process waste water and salt cooling water (SCW).
Process waste water is produced during the refining process. The single largest flow is the
crude oil desalting process where the crude is washed prior to distillation. Other smaller
sources include sour water and boiler blow downs. All of the waste water generated from
these sources is collected by the Refinery’s Sewer System. This water is treated as
contaminated waste water or ‘oily waste water’. Storm water on the process unit areas is
also collected in the Refinery’s Sewer System. All waste water that travels through the
Refinery Sewer is treated by the Refinery’s Waste Water Treatment Plant (WWTP). The
WWTP uses a combination of physical, physiochemical and biological processes to treat
waste water in accordance with the Refinery’s environmental permit. Once treated the
water is discharged approximately 4 km offshore via the Sepia Depression Ocean Outlet
Landline (SDOOL). The Refinery maintains a backup outlet that discharges to Cockburn
sound. The Cockburn Sound outlet has not been used since the commissioning of the
SDOOL line in 2009.
The Location of the Sepia Depression Ocean Outlet (SDOOL).
The Refinery maintains a once through Salt Cooling Water (SCW) system. Sea water is
pumped from Cockburn Sound, passes through the Refinery to cool hydrocarbon streams
and is then discharged back into Cockburn Sound. Under normal operations the SCW does
not come in contact with hydrocarbons as heat is transferred via thermal conduction across
tube bundles. However, in the event of a fault the Refinery’s gravity separators remove oil
Page 12 of 33
to prevent its discharge to Cockburn Sound. The SCW system discharge is routinely
monitored as per the conditions of the site’s Environmental Permit. There were no permit
violations during the reporting period, as such the remaining section for water emissions will
focus on the environmental aspects associated with process water management.
Process Waste Water Treatment Plan
The first stage of treatment at the WWTP is
primary oil removal, where gross oil and
solids are removed by the American
Petroleum Institute (API) Separator. The
recovered oil is sent back to the Refinery for
reprocessing. All waste water then passes
through the Equalisation Tank where it is
kept for an extended period of time. The
Equalisation Tank homogenises the quality of
water flowing through to the remaining units.
At this point pH is checked and adjusted as
necessary. Following equalisation, the water
Some of the micro-organisms in the ASUs
enters the secondary de-oiling section of the that help to break down contaminants in the
plant, which removes suspended sediment process waste water.
and oil particles. This is called the Dissolved
Air Flotation Unit (DAF). Following sediment and oil removal the waste water passes
through the biological section of the plant, the Activated Sludge Units (ASUs). Microorganisms in these units break down dissolved contaminants and nutrients. The ASU’s
contain naturally occurring micro-organisms that feed on the contaminants in the waste
water. In the presence of oxygen, the contaminants are converted to water, carbon dioxide
and nitrogen gas which can be discharged safely into the environment. The water then
passes through the clarification section, where suspended solids settle and are removed.
Prior to discharge the treated process water is monitored as per the conditions of the
Refinery’s Environmental Permit.
Dissolved Air Flotation Upgrade 2011
In 2012 BP Refinery (Kwinana) received a Helios
Award for improvements made to the Dissolved
Air Flotation (DAF) Units. The Helios Awards are
BP’s global recognition programme. The awards
are given to BP projects that demonstrate
commitment to BP’s values. The Refinery’s
winning
entry
demonstrated
the
site’s
commitment to both safety and environmental
responsibility. The Refinery must have at least
one of the two DAF Units running at all times.
Prior to the improvements, the dual DAF System
The Refinery’s Helios Award winners.
Paul Troost, Doug Sweetman and
David Lee.
Page 13 of 33
was very unreliable and each Chain Scraper had to be rebuilt every year. The rebuild put the
Refinery’s maintenance crew at risk and meant that the system was not operating
optimally. The improvements have greatly increased the run time between overhauls, from
11 months to 2 years. It has also reduced the time required for each overhaul from 11
weeks to 3 weeks. The improvements have increased the reliability and effectiveness of the
DAF system and have thereby improved the efficiency and environmental performance of
the Refinery’s WWTP.
Management of Water Emissions
The process water produced during the refining process can potentially contain high levels
of contaminants. These contaminants originate from crude oil or result from chemical
reactions during the refining process. Some key aspects are outlined below.
Hydrocarbons (kg/yr)
Hydrocarbons
1400
The Refinery manages its process water
effluent
to
minimise
hydrocarbon
1200
emissions.
Management
involves
1000
maintaining the processes that produce
water and optimising the treatment
800
efficiency of the WWTP.
Free oil is
600
removed from the process water through
400
the physical and physiochemical processes
of the WWTP. Oil dissolved in the process
200
water is biologically treated in the final
0
stages of the WWTP. Process water is
2010
2011
2012
monitored for hydrocarbons prior to
discharge and must meet the conditions of Annual Hydrocarbon emissions from BP
the environmental permit. Performance for Refinery (Kwinana).
hydrocarbon emissions has been consistent
with historical levels, with the exception of 2012. This can be attributed to a major overhaul
of one of the ASUs during 2012.
COD/BOD
Chemical Oxygen Demand (COD) is a measure of the amount of oxygen required to
chemically oxidise contaminants. COD does not differentiate between biologically available
and inert matter. Biochemical (or biological) Oxygen Demand (BOD) is a measure of the
amount of oxygen required by the biota to oxidise constituents in water.
The concentration of COD and BOD in treated process water is managed by controlling the
process water input to the WWTP and by optimising the treatment process. Education and
communication within the Refinery is essential. Unit Operators are required to control and
manage discharges to the Oily Water Sewer System which may contain high COD and BOD
concentrations. Good communication between process unit operators and the WWTP
operators allows for the management of water inputs. The WWTP can also be adjusted to
Page 14 of 33
58000
57000
56000
55000
54000
53000
52000
51000
50000
49000
48000
9000
8000
7000
BOD (kg/yr)
COD (kg/yr)
maximise the removal of the COD and BOD by changing process conditions on the plant. If
the removal of COD and BOD is not considered adequate then the treated waste water can
be recycled back through the treatment process for additional treatment. Process water is
monitored for COD and BOD prior to discharge and must meet the conditions of the
environmental permit. Performance for COD was variable from historic WWTP averages,
but an overall improvement was evident over the reporting period.
6000
5000
4000
3000
2000
1000
2010
2011
0
2012
2010
2011
2012
Annual COD and BOD emissions from BP Refinery (Kwinana).
TSS (kg/yr)
Total Suspended Solids (TSS)
TSS is a measure of the mass of particles
suspended in the water. TSS in treated
25000
process water effluent is predominantly
carried over from the biological treatment
20000
process. TSS is managed by controlling the
15000
discharges to the WWTP and optimising the
treatment plant conditions. The ASUs
10000
within the WWTP are carefully controlled to
5000
maintain optimum environmental conditions
to keep the population of micro-organism
0
healthy and alive. The feed to the units is
2010
2011
2012
carefully monitored to prevent high levels of
Annual TSS emissions from BP Refinery
contaminants
entering
the
system
(Kwinana).
suddenly. This minimises any shock to the
micro-organisms, resulting in reduced TSS
discharge. The final clarification stage is optimised to remove the maximum amount of TSS.
Process water is monitored for TSS prior to discharge and must meet the conditions of the
environmental permit. Emissions levels were above the historical average, but an
improvement was evident over the reporting period.
Page 15 of 33
Total Nitrogen
Total nitrogen is the sum of ammonia, organic nitrogen, and nitrate-nitrite. Sources of
nitrogen in the process water include;
 Amine, which is used in the refining process to absorb H2S and CO2, and to control
corrosion.
 Sour Water Stripper effluent and
 Fire fighting foam from the fire training ground.
Total Nitrogen emissions are managed by
8000
the Refinery by monitoring the inputs to
7000
the WWTP and optimising the treatment
6000
process accordingly. The Refinery’s WWTP
5000
biological treatment units are specifically
4000
designed to remove nitrogen through the
3000
processes
of
nitrification
and
2000
denitrification. A proportion of the nitrogen
1000
in the process water is converted to
0
nitrogen gas, and this lowers the total
2010
2011
2012
nitrogen discharged from the Refinery to
the aquatic environment. The Process
Annual Total Nitrogen emissions from BP
water effluent is monitored for Total
Refinery (Kwinana).
Nitrogen prior to discharge and must meet
the conditions of the environmental permit. Performance for Total Nitrogen has improved
from historical levels, with the exception of 2012. This can be attributed to a major overhaul
of one of the ASU’s during 2012.
Total Nitrogen (kg/yr)
9000
Overall Environmental Performance for Water Emissions
During 2012 the Refinery had a major TAR Event during which many of the units weren’t
operating under optimal conditions. Additionally in 2012, there was an overhaul of one of the
ASUs in the WWTP. These events affected the waste water influent and the operating
conditions of the WWTP.
BP Refinery (Kwinana) samples the process waste water effluent on a daily basis to meet
environmental permit requirements. Fifteen parameters are analysed on a daily basis and an
additional three parameters are analysed twice weekly. During the reporting period there
was a total of one limit exceedance and two target exceedances. The limit exceedance
occurred in 2012 and was attributed to the start-up of an ASU after a maintenance overhaul.
The permit target exceedances, one in 2010 and one in 2012, were attributed to unplanned
Refinery operations which resulted in abnormal influent to the WWTP. All environmental
permit exceedances are investigated and corrective actions are put in place to reduce the
probability of a reoccurrence.
Page 16 of 33
Soil and Groundwater
Past operational activities at BP Refinery (Kwinana) have resulted in the loss of
hydrocarbons to ground at several locations across the site. These losses resulted from past
operational practises that, due to lack of industry wide knowledge, were considered
acceptable at the time. The original design of the Refinery did not include a drainage system
in the Crude Oil Tank Farm. As a result, water from the Crude Oil Tanks was drained to
ground resulting in the accumulation of hydrocarbons in the substrate.
BP Refinery (Kwinana) first became aware of subsurface hydrocarbons in the 1970s when
extensive monitoring of the subsurface soil was carried out. On detection, recovery efforts
commenced with the use of a vacuum tanker. A recovery program has since developed
with a comprehensive network of subsurface hydrocarbon recovery systems. The
Refinery’s first priority is to avoid environmental impact to the Cockburn Sound by
preventing any further migration of underground hydrocarbons. Additionally, the Refinery
aims to remediate the site through the recovery of subsurface hydrocarbons and the
treatment of impacted groundwater. There is a “no oil to ground” policy across the
Refinery.
Management of Soil and Groundwater Contamination
The loss of hydrocarbons to ground from past Refinery activities has resulted in the
accumulation of hydrocarbons beneath the Refinery. Over time, these losses have resulted
in the formation of subsurface hydrocarbon plumes and the subsequent contamination of
the soil and groundwater. How the Refinery is working towards remediating the
contaminated area and the management actions in place to prevent any further
contamination are outlined below.
Sub-surface Hydrocarbons
Sub-surface hydrocarbons exist in a number of phases (gas, dissolved phase and liquid). The
hydrocarbon can change state and become a soil gas that exists in the spaces between the
soil particles. When hydrocarbon is in contact with the ground water it may form dissolved
constituents, which result in the development of a dissolved phase hydrocarbon plume.
Dissolved phase hydrocarbon plumes are of concern at the Refinery as the contamination
plumes are mobile and reduce the beneficial use of groundwater as a resource. The
hydrocarbon may also remain in its original liquid form. As a liquid it can also exist in
different ways within the soil. The liquid may attach to soil particles, or form isolated
discontinuous droplets referred to as residual hydrocarbon which cannot move or flow. It
can also remain as ‘free hydrocarbon product’ which is mobile and available for recovery.
Free-phase hydrocarbon has the potential to migrate and contaminate other soil or water
resources, including Cockburn Sound.
BP Refinery (Kwinana) is committed to the continuous monitoring, recovery, remediation
and management of accumulated hydrocarbons beneath the site. The management and
remediation strategy is to prevent the loss of hydrocarbons to ground, recover as much of
Page 17 of 33
the subsurface hydrocarbon as possible, prevent the offsite migration of hydrocarbons and
in the long term, remediate soil that has residual (non-mobile) hydrocarbon contamination.
A routine monitoring program has been established to give an early warning of any unseen
leaks or hydrocarbon migration. The Refinery has an extensive network of over 200
monitoring wells installed across the site, including wells that are monitored monthly and
weekly. The wells are used to monitor the distribution of the subsurface hydrocarbon, to
detect any migration of free-phase hydrocarbon and to identify the presence of new leak
sources. All crude tanks are also fitted with electronic gauges that monitor the height of the
fluid and give an early warning of potential leaks and to prevent tank over-fills. A collection
system has been constructed which collects all tank water drainings and directs them to the
Refinery’s Oily Water Sewer System which flows directly to the WWTP. All storm water
and water used in wash down areas is also collected by the Refinery’s Sewer System. Tank
floor leaks are prevented by regular tank inspections. During inspections the tank is taken
out of service, internally cleaned and inspected for corrosion.
The Refinery has an
extensive
network
of
subsurface
hydrocarbon
recovery systems that have
been operating on the site
since the early 1980s.
Subsurface
hydrocarbon
recovery systems currently
in use on the Refinery
include:
hydrocarbon
recovery
trenches/wells,
single-phase hydrocarbon
The various types of Hydrocarbon Recovery Systems utilised
recovery skimmers, solar
by the Refinery.
powered
hydrocarbon
recovery units, dual-phase
hydrocarbon recovery systems and vacuum enhanced product recovery units. Subsurface
hydrocarbons are also recovered from beneath the site using a vacuum tanker.
The Refinery also operates two air sparging lines to remediate hydrocarbon impacted
groundwater that has the potential to migrate offsite. Air sparging is a remediation
technology that involves the injection of air into an aquifer to treat hydrocarbon
contaminants dissolved in the groundwater and trapped in soil pores. The monitoring of
dissolved phase hydrocarbon concentrations at both air sparging sites continues to confirm
that the air sparging systems are effective at reducing hydrocarbon concentrations in
groundwater underlying the air sparging lines.
Page 18 of 33
Environmental Performance
BP Refinery (Kwinana) assesses the effectiveness of the subsurface hydrocarbon recovery
program, based on equipment utilisation targets and free-phase hydrocarbon availability
targets.
Utilisation Targets
The Refinery’s equipment utilisation targets have been established based on the types of
equipment, equipment availability and the annual seasons. The behaviour and distribution of
subsurface hydrocarbon is influenced by seasonal variations in the water table elevation,
due to rainfall recharge and tidal fluctuations. Fluctuations in the water table can cause the
hydrocarbon to be trapped in, or released from pore spaces in the soil. Under high water
table conditions, the amount of free-phase hydrocarbon is low as contact with the
groundwater causes the hydrocarbon to dissolve into constituents. Under low water table
conditions, the amount of free-phase hydrocarbon product increases as water drains from
the pore spaces. Recovery efforts are now focussed in areas of the Refinery where the
free-phase hydrocarbon is persistent throughout most of the year. The recovery equipment
is classified into two groups, non-drawdown recovery equipment and drawdown recovery
equipment. Non-drawdown equipment is passive recovery equipment and includes Single
Phase Recovery Skimmers and Vacuum Enhanced Recovery Units. Non-drawdown recovery
systems are best utilised when water levels are low, usually during the summer and
autumn months. Drawdown recovery equipment is active recovery equipment, and includes
Dual-Phase Recovery Units and Vacuum Tankers. Drawdown recovery systems are best
utilised when water levels are high, usually during the winter and spring months.
Essentially, the yearly internal Equipment Utilisation Targets are set by taking into
consideration the availability of the different equipment types and allowing for seasonal
fluctuations in the water table and its effect on free-phase hydrocarbon availability. The
performance against the Equipment Utilisation Targets, which were set during the 2010 to
2012 period are shown in the table below.
Sub-surface hydrocarbon recovery Equipment Utilisation Targets and
to 2012 period.
Summer (Q1)
(Dec/Jan/Feb)
Equipment Type
Actual Actual Actual
Target
Target
2010
2011
2012
Non-Drawdown
90%
92%
91%
88%
90%
Drawdown
75%
99%
98%
100%
75%
Winter (Q3)
(Jun/Jul/Aug)
Equipment Type
Actual Actual Actual
Target
Target
2010
2011
2012
Non-Drawdown
50%
102%
74%
79%
25%
Drawdown
85%
100%
100%
100%
85%
Percentages for the 2010
Autumn (Q2)
(Mar/Apr/May)
Actual Actual
2010
2011
99%
91%
100% 100%
Spring (Q4)
(Sep/Oct/Nov)
Actual Actual
2010
2011
87%
44%
87%
96%
Actual
2012
98%
100%
Actual
2012
87%
100%
Page 19 of 33
Equipment Utilisation Percentages for 2010 to 2012 period are above the established
Equipment Utilisation Targets, indicating the Refinery was optimising its use of free-phase
hydrocarbon recovery equipment on the site throughout this period.
Availability Targets
The Refinery’s free-phase hydrocarbon availability target was introduced in 2011 and takes
into consideration where the subsurface hydrocarbon recovery equipment is located on the
Refinery in relation to where the free-phase hydrocarbon is located beneath the Refinery. In
principle, the Refinery’s subsurface hydrocarbon recovery equipment should only be located
in areas of the site where free-phase hydrocarbons are present. The Refinery’s free-phase
hydrocarbon availability target is that on a monthly basis, no more than 5% of the Refinery’s
operating hydrocarbon recovery skimmers will be deployed in areas of the site where freephase hydrocarbon is not available. Free-phase hydrocarbon availability percentages for
2011 to 2012 are within the established free-phase hydrocarbon availability target, indicating
all of the Refinery’s free-phase hydrocarbon recovery equipment was deployed in areas of
the site where free-phase hydrocarbon was available during this period.
Solid Wastes
Solid waste is produced as a by-product of crude processing and its related activities. The
types of solid wastes that are generated include tank sludges, contaminated soils, spent
catalysts and other spent chemicals, together with general municipal (household) and
recyclable wastes. The amount and types of waste produced as a result of operations at BP
Refinery (Kwinana), is dependent on unit operation, construction/demolition works and
maintenance activities, and consequently varies from year to year.
Management of Solid Wastes
Waste management is an issue of concern to industry, government and the wider
community. There are three major concerns surrounding solid waste management. The first
concern is the potential loss of valuable and non-renewable materials that could otherwise
be recycled. The second is the use of otherwise valuable land for landfill. The third is the
potential impacts of inadequate disposal techniques on groundwater quality and the
environment, which can ultimately lead to adverse impacts on human health.
BP Refinery (Kwinana) has in place several waste management systems that help to ensure
wastes are handled and disposed of in a responsible manner, generation of wastes is
minimised and recycling/reuse is maximised wherever possible. As part of the BP Group,
the Refinery has a policy to treat wastes in a ‘cradle to grave’ manner. This means that the
generation, movement, treatment, storage and ultimate disposal of wastes is documented,
controlled and meets all regulatory requirements. The Refinery has developed a Solid Waste
Management Plan detailing the typical source, treatment and disposal route for all routine
wastes produced by the Refinery. BP Refinery (Kwinana) has in place procedures that
Page 20 of 33
control the management, handling and disposal of solid waste. The procedures ensure that
all wastes are correctly managed and documented. Permits are required when waste is to
be relocated from the site of generation, to either a storage or disposal location onsite, or
offsite.
Solid wastes generated by the Refinery are either
disposed of directly offsite, treated onsite and then
disposed of offsite, or treated and disposed of onsite.
Municipal (household) waste is managed through the use
of colour coded bins for recyclables and non-recyclables,
emphasis is placed on the importance of reducing the
amount of waste generated and personnel are
encouraged, where possible, to recycle waste that is
produced. For example, in 2012 the environmental team
introduced ‘Keep Cups’. As part of this initiative,
employees are each given a reusable coffee cup and
encouraged to use this at the Refinery’s café instead of
A BP Refinery Kwinana ‘Keep
paper cups. When employees take the cup with them to
Cup’
the café they are given a discount on their coffee. This
initiative has helped to reduce the number of paper coffee cups used on site, and therefore
reduced the volume of waste produced. Municipal wastes are disposed of offsite at
appropriately licenced land fill facilities. Recyclables collected are processed through a
materials resource recovery facility. Other solid wastes generated at the Refinery such as
oily wastes, spent catalysts and industrial/process waste are managed at the Refinery’s
waste management facility. This unique waste management facility is dedicated specifically
for the handling, storage and treatment of these types of solid wastes.
The Refinery is continually looking for ways to reduce the amount of waste sent to landfill
and to minimise any environmental impacts associated with the solid wastes generated by
the Refinery. Over the 2010 to 2012 period the Refinery trialled alternative methods to
improve the performance of sludge disposal and biodegradation. A new and more efficient
online waste management system has also been developed.
In 2011 BP Refinery (Kwinana) conducted a composting trial to determine if composting
could be used to reduce the levels of hydrocarbon in tank sludge which was too high in
hydrocarbon concentration to be safely placed on the Refinery’s Land Farm or landfilled.
Sludge containing high concentrations of hydrocarbons was blended with compost
amendments. These amendments included green waste, mushroom compost, precomposted organic waste and chicken faeces to ensure adequate nutrient, bacteria, fungi
and moisture levels for optimal biodegradation. A unique static composting set up was
established in order to minimise odour and reduce management time. Perforated pipe
extending from the bottom of the static compost pile was used to aid aeration via
convection. Results from the trial found that there was a good reduction in total petroleum
hydrocarbons. However, the reduction in aromatic petroleum hydrocarbons was not
sufficient enough to support the potential large scale use of this form of composting.
Page 21 of 33
On left, an illustration of the aeration of a static compost pile via convection through perforated
pipes. On right, a photograph of the composting trial set up.
In 2012, a trial was conducted in which broad beans were planted in two sections of the
land farm with the aim of reducing active tilling of the soil and the need for nitrogen addition
while, at the same time, improving soil structure and nutrient retention. As a result of the
trial water savings were achieved over the 3 months that the broad beans were growing.
This was due to the fact that the crop coverage reduced the need for dust suppression
spraying. Nutrients were not added to the areas of the land farm planted with bean crops,
however, nutrient levels remained stable in these areas. This indicates that the bean crop
was successful at naturally enriching the soil with nutrients while reducing the risk of
leeching added nutrients into the groundwater.
The 2012 broad bean trial. Broad beans were planted in two of the land farm cells in
order improve soil structure and nutrient retention.
Additionally in 2012, BP Refinery (Kwinana) developed a new online waste management
system. The new system is designed to effectively track waste movements within and out
of the Refinery using a waste permit system. It will also be used to manage laboratory
analysis results and to produce the data required to generate waste inventories and
regulatory reports.
Page 22 of 33
Total Annual Weight (tonnes)
There has been a decrease in the total
amount of non-hazardous waste produced
by BP Refinery (Kwinana) over the 2010 to
2012 period. However waste generation
and offsite disposal differs from year to year
due to changing site activities. The
demolition of an office building in 2009
generated a large amount of construction
and demolition waste which was disposed
of over 2009 and 2010. Over this period the
site also disposed of historical remediated
soil to landfill or for use as clean fill. The
mass of soil disposed of offsite has reduced
over the three years as the backlog of
historical soil has been cleared, this also
explains the overall reduction in waste
disposal over the 2010-2012 period.
Hazardous Waste
45
40
35
30
25
20
15
10
5
0
2010
2011
2012
The total weight and proportions of
hazardous solid wastes disposed of at BP
Refinery (Kwinana).
Total Annual Weight (tonnes)
Environmental Performance for Solid Waste
Non-hazardous waste
(recovery/recycled)
16000
14000
Non-hazardous waste
(disposed offsite)
12000
10000
8000
6000
4000
2000
0
2010
2011
2012
The total weight and proportions of nonhazardous solid wastes disposed of at BP
Refinery (Kwinana).
There was a reduction in hazardous waste
from 2010 to 2011, however in 2012 there
was a significant increase in the amount of
hazardous waste disposed of offsite. This
large increase is due to the disposal of
contaminated sulphur that was previously
stockpiled onsite. The sulphur was
accumulated from maintenance shutdowns
of the SRU since 1999 and, after much
investigation into alternative disposal
options, could not be recycled.
The Refinery will continue to focus on
cleaner and more efficient production to
minimise the amount of solid waste that is
produced. The Refinery will also continue to
seek reuse and recycling options for waste.
Page 23 of 33
Biodiversity
Biodiversity is the variety of all life forms, the different plants, animals and micro-organisms,
their genes and the ecosystems of which they are a part. The processes involved in refining
crude oil have the potential to impact biodiversity and BP Refinery (Kwinana) recognises its
responsibility to protect and maintain the unique balance of native plants and animals in the
areas surrounding the site.
BP Refinery (Kwinana) is located on the edge of the natural harbours of Cockburn Sound.
Originally the area was predominately covered in what is known as the Quindalup
Vegetation Complex. This included Herb-lands, Sedge-lands and Acacia Shrub-lands. Today
the Refinery still has two patches of native Quindalup Vegetation on site. These areas have
been protected from destruction through the prevention of public access.
The small areas of remnant vegetation are inhabited by a population of native Southern
Brown Bandicoots (Isoodon obesulus fusciventer). This species of bandicoots is classed as
a ‘conservation dependant priority species’. In 2012, BP Refinery (Kwinana) established a
bandicoot monitoring program. Motion activated cameras were set up around the reserve to
capture photos of the shy and mostly nocturnal animals. The monitoring program was
developed in collaboration with Coast Care, who has established a long term bandicoot
monitoring program at Challenger Beach in Naval Base (Kwinana). The photos captured by
the cameras will be used to establish an estimate of population size and structure. The
information gathered will be used to help monitor and protect the bandicoot population and
their remaining habitat, and to educate and raise awareness.
Left: One of many photos of bandicoots captured at the BP Refinery (Kwinana) Site. Right:
One of the motion sensored cameras used to capture Bandicoot photos.
In 2011, BP Refinery (Kwinana) initiated a formal partnership with Native Arc. The funding
provided by the Refinery, was used to buy materials to build enclosures for the three stage
rehabilitation of orphaned ducklings. Volunteers from the Refinery helped to build one of the
enclosures and assisted in the release of rehabilitated ducks. Over 250 ducklings were
Page 24 of 33
cared for in that year with a greater than 90% success rate achieved. BP Refinery (Kwinana)
continued the partnership in 2012 and the funding provided went towards enclosures for
bandicoots and raptors. Volunteers from the Refinery helped to build the enclosures and
participated in the release of wildlife as was needed.
BP Refinery (Kwinana) Volunteers building wildlife enclosures and helping with the
rehabilitation of ducklings at Native Arc, Bibra Lake, 2011.
BP Refinery (Kwinana) also initiated a partnership with Coastcare in 2011. Through this
partnership, the Refinery adopted a degraded area of coastal dune at the Governor Road
Reserve in the City of Rockingham. Over the first two years (2011 and 2012) of this
partnership, funding has helped to restore the coastal vegetation at the site. BP volunteers
planted native species suited to the coast to improve habitat for native animals and to
protect the coastal dunes from erosion.
BP Refinery (Kwinana) Volunteers planting native coastal species at the Governor Rd
Reserve, July 2011.
Page 25 of 33
Water Usage
Using water is an essential part of the refining process. BP Refinery (Kwinana) requires
water for a variety of purposes. For example, it is used to heat and cool the hydrocarbon as
it is refined into useable products. Water is also used to remove impurities in the
hydrocarbon and to perform maintenance activities. The Refinery utilises a number of
different water sources for a variety of different purposes. Steam is used in a number of
different areas within the Refinery, it is generated onsite and purchased from the Kwinana
Cogeneration Plant. Potable water from the Water Corporation is used for processes
requiring high grade water, such as boiler feed water, drinking water, safety showers and
eye wash stations. Treated high quality waste water from the Kwinana Water Recycling
Plant (KWRP) is used in place of potable water wherever possible. Low grade water, which
consists of groundwater and returned/reused process water, is used for other processes.
Management of Water Usage
BP Refinery (Kwinana) is conscious of the need to conserve water and of its high value as a
resource. A focus on water minimisation has increased in recent years in response to
reduced rainfall and increasing demands on the local water supply. BP Refinery (Kwinana)
participates in the Water Corporation’s Water Efficiency Management Plan (WEMP)
program. As part of this plan the Refinery has in place a ‘Water Reuse and Minimisation
Program’ which was implemented in 1997.
The objectives of the program are:
-To reduce total water use (by minimising use and increasing reuse),
-To significantly reduce potable water use, and
-To achieve zero discharge of process wastewater to Cockburn Sound.
This innovative program approaches water management with a whole refinery perspective,
whilst at the same time targeting specific areas of high water use. Water use minimisation
is an on-going practise within the Refinery, and implementing simple actions on the ground,
such as fixing dripping taps and only running hoses when necessary can be effective in
minimising water use.
In the 1990s BP Refinery (Kwinana) was
the largest potable water user in Perth.
The Refinery has since decreased its
potable water usage to approximately
10% of the 1990’s levels. This
significant water saving achievement
has been recognised by the Water
Corporation, which in 2012 presented
BP Refinery (Kwinana) with a Platinum
Award for water use. The award
Des Gillen accepting the Refinery’s Platinum
Award for improved water use efficiency.
Page 26 of 33
recognises that the Refinery has improved its water use efficiency by more than 50%.
Much of this reduction was achieved though substituting the use of potable water, for
processes such as steam generation and cooling, with highly treated waste water from the
Water Corporation’s Kwinana Water Recycling Plant (KWRP).
Environmental Performance for Water Use
Average Potable Water
Use (kL/Day)
700
600
500
400
300
200
100
0
2010
2011
2012
Average potable water use at BP Refinery
(Kwinana).
4500
Average Total Water Use
(kL/day)
There has been an overall reduction in daily
total water use at BP Refinery (Kwinana)
over the 2010 to 2012 period. The
reduction over this period can be attributed
to improvements in the accuracy of the
groundwater abstraction measurement.
Additionally, improvements in energy
efficiency saw a reduction in the amount
of steam used by the Refinery from 2010
to 2011. From 2011 to 2012, there was a
reduction in the amount of treated waste
water from KWRP that was used, this was
due to the 2012 TAR (Turn Around or
maintenance event) during which many of
the Refinery’s process units experienced
significant down time, and hence water
requirements were reduced.
4000
3500
3000
2500
2000
1500
1000
500
0
2010
2011
2012
Average total water use at BP Refinery
(Kwinana). Total water use includes potable
water use, groundwater use, KWRP treated
waste water use and imported steam use.
Despite the decrease in the Refinery’s daily
total water use over the 2010 to 2012
period, the Refinery’s use of potable water
has remained consistent with typical usage.
Temporary issues with the operation of
groundwater production facilities in 2012
resulted in potable water being used to
supplement the Refinery’s groundwater
supply. The large increase in the number of
personnel onsite due to the 2012 and 2010
Refinery TARs would have also contributed
to the increase in potable water.
The Refinery commits to an annual water
efficiency target with the Water Corporation as part of the WEMP. The Refinery also sets
internal targets for water use as a component of the site’s EMS.
Page 27 of 33
Public Nuisance
Refinery operations have the potential to produce elevated noise and various odours. This
has the potential to adversely affect the local environment, in particularly the other
industries which boundary the Refinery, and the surrounding residential areas. BP Refinery
(Kwinana) manages the various refining processes so that odours emanating from the
premises do not unreasonably interfere with the health, welfare, convenience, comfort or
amenity of any person at odour sensitive premises. Under the Environmental Protection
(Noise) Regulations 1997, BP Refinery (Kwinana) is required to maintain noise levels below
acceptable and permitted levels at all times of the day. The significant environmental
aspects related to odour and noise emissions are outlined below, along with their potential
impacts and how they are managed.
Management of Public Nuisance
Noise
The process of refining crude oil to useful products is complex and requires equally complex
equipment which produces noise simply due to the fact that it is made up of moving
mechanical parts. Noise is also emitted from pressure drops across equipment from release
valves, from high gas/steam flow rates exiting stacks and from the flares. The potential
impacts of noise can vary greatly depending on the level and type of noise emitted. Possible
impacts can range from behavioural effects such as reduced attention, reduced problem
solving ability and disturbed sleep, to more serious hearing impairments and hypertension.
Noise emissions from the Refinery are managed using engineering solutions and by
managing the operation of equipment. Engineering solutions to control noise are applied to
both new and existing equipment.
Odour
The Refinery is a complex facility with a number of possible sources of odour emissions.
This is due to the range of different substances that are used in the refining process.
Potentially odorous substances include crude oil, catalysts, cleaning agents, additives and
wastes, as well as refining by-products and final products. Human exposure to odour
generally results in one of three responses or impacts; these are health effects, annoyance
or stress. To manage odour emissions, BP Refinery (Kwinana) has in place an internal Odour
Management Procedure. The procedure outlines the characteristics of eight gases which
could potentially cause offsite incidents of odour. The characteristics of the odour can then
be used to trace the odour back to the particular units which are likely to be the source of
the odour. The Odour Management Procedure also outlines how to avoid producing odours,
and how to respond in the case of odour detection. Additionally, the Breaking Odorous
Lines Procedure provides an overview of the actions to consider before commencing an
activity that could potentially result in the venting of odorous substances, including
consideration of weather conditions and methods to prevent odours.
Page 28 of 33
Environmental Performance for Public Nuisance
Over the 2010 to 2012 period BP Refinery (Kwinana) received no noise complaints from the
surrounding industries or community. Noise emissions have been significantly reduced
since 2008 after a silencer was installed on the Residual Cracking Unit (RCU). The RCU
stack was previously identified as a dominant noise source within the Refinery. A silencer
was subsequently installed in the upstream ducting of the RCU exhaust stack to reduce
noise levels. Noise surveys
conducted before and after the
installation of the silencer, show
that the silencer has provided a
net reduction of 10 dB in the
noise emissions from the unit. BP
Refinery (Kwinana) plans to
continue making improvements in
reducing noise emissions from
the
Refinery.
Future
Improvements are focussed on
installing noise efficient devices
on new projects and addressing
The RCU silencer installed in 2008 at BP Refinery
high noise point sources on site.
(Kwinana).
BP Refinery (Kwinana) had no odour complaints from the community during 2010 or during
2012. However in 2011, there were two events that resulted in odour complaints from the
neighbouring industrial community. Both of the odour complaint events were investigated
with findings resulting in corrective changes to operating procedures. The information
gathered from investigations into the causes and sources of odour emissions will help to
ensure future odour emissions can be managed and prevented. The Refinery will continue
to manage potentially odorous sources and activities to minimise any offsite impact.
Page 29 of 33
Verification Statement
Page 30 of 33
Contact Details
Should you require any further information, or if you have any questions about this report or
BP Refinery Kwinana’s operations in general, please contact us and we will be happy to
assist.
Contact Information
Craig McNaughton
Environmental and Dangerous Goods Superintendent
BP Kwinana Refinery
PO Box 2131
Rockingham, WA 6168
AUSTRALIA
Tel:
Fax:
+61 8 9419 9500
+61 8 9419 9800
Page 31 of 33
Acronym Glossary
API Unit
ASU
BOD
CEM
COD
CO2
CDU
DAF Unit
DEC
EMS
ISO
KWRP
NC
NOx
PER
PM
RCU
SCW
SDOOL
SOx
SRU
TAR
TSS
WEMP
WWTP
VOCs
American Petroleum Institute Unit
Activated Sludge Unit
Biological Oxygen Demand
Continuous Emissions Monitor
Chemical Oxygen Demand
Carbon Dioxide
Crude Distillation Unit
Dissolved Air Flotation unit
Department of Environment and Conservation
Environmental Management System
International Standard Organisation
Kwinana Water Recycling Plant
Nameplate Capacity (Maximum crude oil throughput expressed in kilo Barrels
per Day)
Nitrogen Oxides
Public Environmental Report
Particulate Matter
Residual Cracking Unit
Salt Cooling Water
Sepia Depression Ocean Outfall Line
Sulphur Oxides
Sulphur Recovery Unit
Turn Around Event (Shutdown/Maintenance Event)
Total Suspended Solids
Water Efficiency Management Plan
Waste water Treatment Plant
Volatile Organic Compounds
Page 32 of 33

Public Environmental Review 2010-2012

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