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WESFARMERS SUSTAINABILITY REPORT 2017

2017 WesCEF Potential non-conformance notice

The table below outlines the potential non-conformances identified across WesCEF Operations during 2016-2017.  Of note, 19 out of the 25 events were internally identified by WesCEF personnel through proactive assessment practices, representative of the strong commitment WesCEF has to continual improvement and regulatory compliance.

Location

Summary

Description

CSBP Albany (1)

Wastewater discharge limits were not met on one out of 24 events.

The wastewater licence concentration limit was exceeded on one occasion for one (Total Phosphorus) out of seven analytes.  The volume of water discharged with Total Phosphorus concentration above the licence limit was 2,238m3 out of a total annual discharge volume of 89,748m3 (2.5%). No impact was observed from this event.

CSBP Bunbury (13)

Non-scheduled irrigation to onsite tree farm occurred 12 times to prevent storm water discharging directly into the Preston River.

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 rainfall,  irrigation is undertaken outside of the approved strategy to prevent the dam from overtopping and discharging directly into the Preston River.  No impact was observed from any of these events.  A potential water treatment solution has been identified and is currently being assessed, which will remove the need to emergency irrigate stormwater.

Irrigation strategy criteria not met on one occasion out of 179 irrigation events.

The regulator approved irrigation strategy contains agreed water quality criteria, which were exceeded on one occasion.  No impact was observed from this event and a potential water treatment solution has been identified and is currently being assessed, which will remove the need to irrigate stormwater.

CSBP Geraldton (3)

Calibration of pH meter was not carried out prior to testing water samples on five out of 13 occasions.

The Environmental Protection Act 1986 licence requires the pH meter to be calibrated prior to each use.  There was no impact as a result of not performing the calibration and personnel have been retrained in the use of the meter.

Three water samples were analysed for dissolved magnesium and potassium instead of total magnesium and potassium.

The Environmental Protection Act 1986 licence specifies total magnesium and potassium analysis. The error has been rectified and new instructions issued to the external laboratory.

 

Elevated nitrogen relevant to background was identified in a single groundwater bore downgradient of lined pond indicating the pond is leaking.

The Environmental Protection Act 1986 licence states the Licensee shall manage all stormwater ponds so that the integrity of the containment infrastructure is maintained. Inspection of the HDPE liner identified some holes and it has since been replaced.

CSBP Kwinana (2)

Approximately 5,600L of liquid UAN fertiliser leaked from an open valve on a temporary import pipeline while unloading a ship.

CSBP reported the incident to the Department of Water and Environmental Regulation and impacted soil has been remediated.  The temporary pipeline has been removed from service.

Department of Fire and Emergency Services Emergency Response Guides (FES-ERGs) do not exist for CSBP Kwinana Fertilisers.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires an operator to have approved Emergency Response Guide available on site. Emergency Response Guides have been prepared and have been submitted to the Department of Fire and Emergency Services.

Kleenheat Beach Street (4)

Electrical equipment in hazardous area was not equipped with earth straps.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires ignition sources to be appropriately managed and at the time of the audit, some electrical equipment did not have earth straps fitted. Earth straps have since been fitted.

Installation drawings had not been developed for  electrical equipment in hazardous areas.

The Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 requires ignition sources to be appropriately managed and at the time of the audit, electrical drawings did not exist. The development of electrical drawings has commenced and they will be completed by 31 December 2017.

Transport of unodourised Liquefied Petroleum Gas (LPG) not fully compliant with the Australian Dangerous Goods (ADG) Code.

The Dangerous Goods Safety (Road and Rail Transport) Regulations 2007 requires compliance with the ADG Code. A Department of Mines, Industry Regulation and Safety Inspector identified that a number of aspects of the ADG Code were not being met.  The Permit to Work system has been updated to more thoroughly cover maintenance tasks undertaken in remote locations.

Incorrectly licensed road tankers used for the transport of Dangerous Goods Class 3 Flammable Liquids.

LPG tankers licensed for the transport of Dangerous Goods Class 2.1 Flammable Gases were being used to transport Class 3 Flammable Liquids.  The breach was administrative in nature and an interim exemption has been obtained while the licence is formally amended.

Kleenheat Operations - Channel Island (2)

Security drill not completed.

The approved Maritime Security Plan requires security drills to be conducted at least annually, however a drill had not been conducted.  An audit against the security plan has been completed and a security drill has been scheduled.

Security plan contact details not kept current.

The Maritime Transport and Offshore Facilities Security Act 2003 requires that key contact details in approved security plans be updated within 48 hours after change and this timeline was not met.  Contact details have since been updated.

GRI 307-1, GRI 413-2