2016 WesCEF Potential Non-Conformance Notice

2016 WesCEF Potential Non-Conformance Notice

 

The table below outlines the potential non-conformances identified across WesCEF Operations during 2015–16. Of note, 27 out of the 31 events were internally identified by WesCEF personnel through proactive assessment practices, representative of the strong commitment WesCEF has to continual improvement and regulatory compliance.

 

CSBP Albany (2)

The minimum freeboard requirement stipulated by the environmental licence was not maintained in the lined stormwater storage pond on one occasion.

The Environmental Protection Act 1986 licence requires at least 400mm freeboard (distance) to be maintained between the water surface and the top of the lined stormwater storage pond to provide a safeguard to overtopping. Under intense rainfall conditions, the pond level can rise faster than the water treatment plant can process and discharge water. The pond did not overflow during any of these events.

Asbestos register not completed.

The Occupational Health and Safety Regulations 1996 require an asbestos register to be prepared if asbestos is present on site. The historic register could not be located and a new register has since been completed. Personnel were not exposed to asbestos.

CSBP Bunbury (16)

Non-scheduled irrigation to the tree lot occurred 13 times.

Water in the lined stormwater dam is used to irrigate the tree lot in accordance with a regulator approved irrigation strategy; however during persistent heavy rain irrigation is undertaken outside of the approved strategy to prevent the dam from overtopping and potentially discharging into the Preston River. No impact was observed from any of these events.

Irrigation strategy criteria not met on three occasions.

The regulator approved irrigation strategy contains agreed water quality criteria, which were exceeded on three occasions. No impact was observed from any of these events.

CSBP Esperance (1)

Asbestos register not completed.

The Occupational Health and Safety Regulations 1996 require an asbestos register to be prepared if asbestos is present on site. The historic register could not be located and a new register has since been completed. Personnel were not exposed to asbestos.

CSBP Geraldton (3)

Spilled liquid fertiliser was manually washed from a bunded area into a lined stormwater storage dam.

The Environmental Protection Act 1986 licence only permits stormwater to be directed into the lined stormwater storage dam, not liquid fertiliser. No fertiliser came into contact with the environment.

Operator unaware of Environmental Protection Act licence condition.

An Operator who washed spilled fertiliser from a bund into a lined stormwater storage dam was not aware that this was prohibited under the licence. The licence requires that all personnel are required to be aware of the licence conditions relevant to the tasks they are performing. The operator has been trained and the environmental awareness training program reviewed to ensure personnel are aware of their environmental responsibilities.

Asbestos register not completed.

The Occupational Health and Safety Regulations 1996 require an asbestos register to be prepared if asbestos is present on site. The historic register could not be located and a new register has since been completed. Personnel were not exposed to asbestos.

Kleenheat Geraldton (3)

Suitable signage was not in place at a dangerous goods storage area.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires suitable warning signs to be placed at dangerous goods storage areas. Signage has since been installed.

Information relevant to potentially dangerous situations had not been provided to neighbours.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires an operator to provide its neighbours with information relevant to potentially dangerous situations that may occur on site. Relevant information has since been provided to neighbours.

An approved Fire and Emergency Services Emergency Response Guide was not available on site.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires an operator to have an agreed Emergency Response Guide available on site. An approved Emergency Response Guide has since been implemented.

CSBP Kwinana (5)

An approved Fire and Emergency Services Emergency Response Guide had not been prepared for Nitric Acid Plant 3.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires an operator to have an agreed Emergency Response Guide available on site. An approved Emergency Response Guide has since been implemented.

The quantity of dangerous goods being stored in a cooling tower chemical bund in Nitric Acid Plant 1 exceeded the approved manifest quantities.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires the operator to maintain a current dangerous goods manifest and to not exceed this upper limit. The manifest has since been updated.

The quantities of dangerous goods being stored at Nitric Acid Plants 1, 2 and 3 exceeded the manifest quantities.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires the operator to maintain a current dangerous goods manifest and to not exceed this upper limit. The manifest has since been updated.

The quantities of dangerous goods being stored at Prill Plant 2 exceeded the manifest quantities.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires the operator to maintain a current dangerous goods manifest and to not exceed this upper limit. The manifest has since been updated.

Evidence could not be provided to confirm that a transport operator was authorised to collect product from Prill Plant 2.

According to the Dangerous Goods Safety (Security Sensitive Ammonium Nitrate) Regulations 2007, a person cannot be supplied with Ammonium Nitrate without evidence that the person is authorised to receive it. Administration procedures have since been amended to ensure up to date authorisations are maintained on site.

Kleenheat Beach St Depot (1)

Condensate and calibration gases were not captured in the dangerous goods register and Safety Data Sheets (SDS) for these products were not available.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires that the Dangerous Goods Register is kept current and that SDS’s are available. The Register has since been amended and SDS’s obtained.