Huntsman Corporation Australia Pty Ltd Botany Site NSW Environment Protection Licence 7494 Reporting Period: 23-12-2015 to 22-12-2016 Vent Management System Annual Report 2016 A. Company and site details Company Name Huntsman Corporation Australia Pty Ltd Company Site Address 77 Denison Street Hillsdale NSW 2036 (Botany Industrial Park) Environment Protection Licence No. 7494 NSW EPA Website Link NSW Environment Protection Authority (EPA) B. Monitoring point details Monitoring Requirement Monitoring Point Number 1 2 3 Description Discharge to atmosphere from Vent Management System (VMS) scrubbing column Flowrate of VMS scrubbing liquor measured by FI 19308 (flow indicator) Conductivity of VMS scrubbing liquor measured by CI 19309 (conductivity indicator) Frequency Annual Continuous Continuous Pollutant Ethylene oxide Propylene oxide - - Unit kg/ hour cubic metres/ hour (m 3 /hr) millisiemens/ centimetre (ms/cm) Lower Limit - - 24 80 Upper Limit 0.22 6.05 - - Averaging Period 1 hour 1 hour - - Plant Conditions during Monitoring 1 Ethylene oxide storage tanks must be venting to the VMS Propylene oxide road tanker must be unloading to storage tank - - Note 1: The mass emission rates that are measured during the VMS Annual Test are representative of emission rates under an infrequent peak loading situation and are not representative of the emission rates that occur for the majority of the time.
C. Monitoring results for 2016 Monitoring Results Date data obtained Monitoring Point Number 1 2 3 17 th August 2016 January 2016 December 2016 Pollutant Ethylene oxide Propylene oxide - - Unit kg/ hour cubic metres/ hour millisiemens/ centimetre Results (i) < 0.000001 < 0.000001 Plant Conditions during Monitoring Propylene oxide tanker unloading to storage tank, Ethylene oxide storage venting to VMS See charts below (ii) < 0.0000004 < 0.000001 Plant Conditions during Monitoring Propylene oxide tanker venting down, Ethylene oxide storage venting to VMS Monitoring Point 1 Results from the sampling at Monitoring Point 1 complied with the upper limit requirement. The results were below the limit of measurement for the instrumentation. Monitoring Points 2 and 3 The charts below show the results for continuous monitoring at Monitoring Points 2 and 3 of the VMS for 2015. Monitoring Point 2: Flowrate of VMS scrubbing liquor measured by FI 19308 (flow indicator) lower limit of 24 cubic metres/ hour flowrate Monitoring Point 3: Conductivity of VMS scrubbing liquor measured by CI 19309 (conductivity indicator) lower limit of 80 millisiemens/ centimetre conductivity VMS Performance Full year 2016 Huntsman has complied with the process conditions set in EOPO Licence 7494 (as amended 30- August 2016) for operation of the VMS. The licensed parameters are;
VMS - Scrubber liquor conductivity above 80 ms/cm CHART 1 VMS - Scrubber flow maintained above 24 m3/hr CHART 2 The charts show compliance to these requirements, for the 2016 calendar period, with the following clarifications; Brief Interruptions The charts show compliance to these requirements, with a few brief interruptions. Flow was lost due to pump trip tests, which total 80 seconds of flow below target (99.999% online). Conductivity was always above target there was a 2 second period of spurious signal. Note that scrubber takes several minutes to drain, therefore scrubber continues to remove oxide during these brief flow interruptions. Additional descriptions of each of these interruptions are included below. Also included (in appendices) are charts zoomed into the event times to confirm duration of each event.
CHART 1 DCS Trend for VMS Scrubber Liquor Flow CHART 2 DCS Trend for Liquor Conductivity
CHART 3 VMS Scrubber Liquor Flow Events There were 4 flow events that require scrutiny. Event 1 Pump trip tests 26-Jan-2016 Electric pump was tripped and diesel back-up pump started. Flow was re-established. Event 2 Pump trip test 5-Sep-2016. Testing conducted during planned total plant shutdown for preventative maintenance. Event 3 Pump trip and restart 20-Sep-2016 Duty pump was tripped and backup pump started automatically and reestablished flow in 10 seconds. Event 4 Pump trip and restart 1-Nov-2016 Duty pump was tripped and backup pump started. Flow was reestablished within in 10 seconds. Note that the test procedure has now been modified so that the duty pump is retained on-line while the automatic start of the backup pump is tested. This is indicated in the chart where the recirculation flow has increased to 70 m3/hr for short periods.
APPENDICES Additional records for events The charts below have zoomed into the event times to confirm duration of each event. Event 1 Pump trip tests 26-Jan-2016 Duty pump was restarted, total period of lost flow was 20 seconds (Note that scrubber takes several minutes to drain, therefore scrubber continues to remove oxide)
Event 2 Plant shutdown 5-Sep-2016. Pump shutdown as a result of planned total plant shutdown for preventative maintenance and routine trip & alarm testing. Restart of pump total of 40 seconds when flow was less than 24 m3/hr
Event 3 Plant trip tests 20-Sep-2016. Pump trip test and automatic start of back-up pump 10 seconds when flow was less than 24 m3/hr Note that scrubbing column takes several minutes to drain, therefore scrubber continues to remove oxide.
Event 4 Event 3 Plant trip tests 1 Nov-2016. Pump trip test and automatic start of back-up pump 10 seconds when flow was less than 24 m3/hr Note that scrubbing column takes several minutes to drain, therefore scrubber continues to remove oxide.