REPORT ON A PUBLIC CONFERENCE UNDER SECTION 20B OF THE ENVIRONMENT PROTECTION ACT 1970.

Transcription

1 REPORT ON A PUBLIC CONFERENCE UNDER SECTION 20B OF THE ENVIRONMENT PROTECTION ACT CONFERENCE HELD IN RESPECT OF WA71437 THE WORKS APPROVAL APPLICATION RELATING TO THE CONSTRUCTION OF ADDITIONAL GAS CONDITIONING PLANT LOCATED AT GARRETS ROAD, LONGFORD, TO REMOVE CARBON DIOXIDE AND MERCURY FROM GAS PRODUCED OFFSHORE. Report prepared by the Chairperson: Keith Greaves, Chit Chat Pty Ltd Section 20B conference venue: Longford Community Hall South Gippsland Highway Longford Date of Section 20B conference: 25 th March 2013 Date of Chairperson s report: 12 th April

2 Table of contents 1. INTRODUCTION 2. REVIEW OF PUBLIC SUBMISSIONS 3. PROCESS AGENDA OF THE CONFERENCE 4. ISSUES, CONCERNS & QUESTIONS RAISED AT THE CONFERENCE 5. PARTICIPANT FEEDBACK 6. CHAIRMAN S CONCLUSIONS AND RECOMMENDATIONS APPENDIX Appendix 1: Summary of questions raised by participants at the 20B in response to the EPA summary concerns relating to WA

3 1. INTRODUCTION EPA accepted a works approval application from Esso Australia P/L (Esso) to construct additional gas conditioning plant at Garrets Road, Longford on 21 st December Esso proposes to remove carbon dioxide and mercury from gas produced offshore. Gas from the gas conditioning plant will be further processed using the existing Esso Longford gas plants before sale. EPA requested community comments about this application through an advertisement in the Herald Sun and Sale Gippsland Times on 20 th January 2013 and a second readvertisement in the same publications on 20 th and 22 nd February 2013 respectively. EPA also referred the application to the Department of Health, Wellington Shire Council and Worksafe for comments. Full responses from these agencies can be downloaded via the EPA website at The period for comments closed on 15 th March 2013 and 50 written submissions were received. A summary of these submissions have been included in Appendix no. 1. The Authority shall take into consideration the discussions and resolutions of any conference under this section and the recommendations of any person presiding at that conference. Section 20B, Environment Protection Act, 1970 To enable EPA to gain a further understanding of the issues that have been raised through the submissions, EPA invited interested parties to attend a public conference, in line with section 20B of the Environment Protection Act, This report outlines the discussions and key issues identified at the conference and includes recommendations for EPA to consider as part of the evaluation of the WA application. A final decision is currently scheduled to be reached on the WA by the EPA by 21 st April Wellington Shire Council are due to determine the results of a planning permit for the same facility in April

4 2. REVIEW OF PUBLIC SUBMISSIONS In preparation for the 20B Conference the following themes and key issues were extracted from the 50 written submissions received by the EPA. Key issues only relate to the areas were EPA have a statutory role, refer to table 1 below. Other areas of concern contained in these submissions have been summarised in table 2 below. Table 1 Theme No. 1 Emissions Best Practice No. 2 Management of mercury Key issues that ARE within the regulatory role for EPA for the purpose of assessing this WA Submissions question whether the proposal represents best practice as required by the State environment protection policy (Air Quality Management). Application assumes that mercury is managed at other sites. Submissions question whether this is adequate? No. 3 Noise from the plant No. 4 CO2 Management No. 5 Performance of existing plant No. 6 Major Hazard Facility No. 7 Air Emissions No. 8 Health Issues Submissions note that the existing plant currently exceeds EPA noise guidelines. The submissions suggest that to increase the noise is not acceptable. A submitter suggests that vibration should also be assessed. Submissions question as to whether the discharge of CO 2 to the atmosphere generated by the process is appropriate. Submissions have raised about the noise, odour and health risk of the plant and whether these are acceptable. Submissions also question whether Esso complies with its licence and ask if this means that Esso fails the fit and proper person test. The submissions ask will the existing plants be able to cope with the ongoing operation and extension of life resulting from the GCP operation? Submissions state that the site is a major hazard facility and comment that the Major Hazard Facility ( MHF ) licence in the application is not the current licence. The submitters believe that EPA should consult Worksafe as to whether application should proceed. Submissions question the impacts on air emissions on health and drinking water. Submitters suggest that the Longford facility should be the subject of ambient monitoring for air pollutants. Submitters state that the plant already impacts on health. In particular effects of hydrocarbon emissions from the plant on local residents. Submitters question on this basis are 4

5 Theme Key issues that ARE within the regulatory role for EPA for the purpose of assessing this WA increased plant emissions acceptable? No. 9 Age of plants (Gas Plants 1, 2 and 3) No. 10 Advertising and process No. 11 Fire risk The GCP is a front end to the existing gas plants. The submissions state that when end of the life of the GCP occurs Gas Plant 1 will be nearly 90 years old and asks is this acceptable? Submitters have questioned as to whether the notification been adequate. A submitter has requested that EPA hold a 20B conference to consider the matter. A submitter questions whether the additional plant will result in increased risk of fire or during a fire. Table 2 Theme Whether EES is required Use of water under existing licence Concerns that ARE NOT within the role for EPA in relation to the assessment of this WA Minister for Planning has decided and published reasons for the decision. This process is not able to revisit that decision. Southern Rural Water is responsible for licences to use groundwater. EPBC Act Vegetation Removal Transport issues Coal seam gas as an input to the GCP The production of the gas from the Kipper Tuna- Turrum field Application of the EPBC Act is a matter for the Commonwealth Minister. Issue for Wellington Shire, DPCD and DSE. Issue for Planning Authority. Issues raised that gas conditioning plant will facilitate a coal seam gas industry. The application is for a plant to process gas from off-shore. This is outside EPA s consideration for this application. Submissions question whether the KTT field should be produced given its lower quality (higher CO 2 concentration). Submitters suggest that there are energy sources that should be preferred that result in lower emissions of greenhouse gases. The question of whether any gas field should be produced is not within EPA s jurisdiction. 5

6 3. PROCESS AND AGENDA FROM THE CONFERENCE The following summarises the stages and logistics surrounding the 20B conference. Location and Date The conference was held from 5.30 to 8.30pm on Monday 25 th March 2013 at the Longford Community Centre, South Gippsland Highway, Longford. Attendees 22 local residents 6 Esso representatives 5 EPA officers 3 administrators Administration Keith Greaves, Chairperson, Chit Chat Janine Dridan, Engagement Facilitator, Strategic Relations, EPA Leanne Kamphuis, Note taker, EPA EPA John Frame, Assessing Officer, Development Assessments, EPA Tim Eaton, Manager, Development Assessments, EPA Janine Dridan, Engagement Facilitator, Strategic Relations, EPA Dieter Melzer, Manager Gippsland, EPA David Guy, Environment Protection Officer, Gippsland, EPA Esso David Standfield, Project Manager, Longford GCP Project Louise Mayboehm, Safety Security Health and Environment Lead, Longford GCP Project Peter Symes Engineering Manager, Longford GCP Project Michael Greenwood, Environmental and Regulatory Advisor - Longford GCP Project Ron Reinten, Safety, Health, Environment & Security Manager, Esso Australia Jeff Robbins, Longford Plants Operations Superintendent Meeting Purpose At the beginning of the evening the following objectives for the 20B conference were stated by the chairperson and displayed on A0 format posters on the walls of the meeting room: 1. For the EPA and Conference Chair to have an understanding of community concerns and issues with the proposal 2. To clarify process, procedures & timelines involved for EPA decision making 3. To identify potential options for EPA and the applicant to consider to address community concerns and issues with the proposal 6

7 4. To capture an accurate record of public ideas and concerns for consideration by the EPA Decision Making Meeting Process What issues can the EPA making decisions about, set out on wall posters as per tables no. 1 and 2 on pages 4/5 of this report. The process for the conference was designed in consultation with representatives from EPA. The process was designed to ensure all participants had the opportunity to put their perspectives forward, and ask questions and raise concerns about the application. Arrival and room set up Participants were welcomed by EPA hosts and asked to register their contact details, produce a first name tag and invited to review the summary of the submissions and other conference data spread around the room on A0 posters. Catering was offered to allow some networking time and the conference began at approx. 5.50pm. Participants were seated at arc shaped clusters of upto 6 chairs to allow community member intermittent opportunities for small group discussion to assist with the overall questioning and issues identification for the first half of the conference. In the second half of the conference participants were seated in two large arc shape seats with a panel of ESSO and EPA representatives in the middle to address questions and comments from the floor. Large format, A0 scale, posters were displayed along the walls of the meeting room and contained the following data: 20B conference purpose statement An introduction note from the chair Clarification of what issues could and could not be considered as part of the WA process Key dates for the overall process 11 x Summary issues posters as per pages 4 & 5 of this report A guideline for the conference discussions Images from the 20B conference at Longford on 25th March 2013 Welcome and context The participants were welcomed by EPA officer, Dieter Melzer. Dieter recognised that the EPA were aware of the permit planning process with Council and noted that EPA is required to make a decision specifically relating to the works application, key issues from this having been highlighted in the room on the summary posters. Participants were thanked for giving their time to allowing further clarification of these concerns. 7

8 Participant Feedback Following Dieter s welcome and context the Chairperson, Keith Greaves, explained the content on the posters, clarified the purpose of the 20B conference, the areas of decision making the EPA had to focus on and highlighted the main steps involved in the assessment process. The chair clarified that the works approval process is independent from the planning permit process and where appropriate any concerns falling outside the WA would be referred to other agencies. The remainder of the conference was given to a whole group participatory process to have a facilitated discussion around the 11 key summary themes identified by the EPA from the 50 written submissions they received. The Chairperson firstly requested a review of all key themes by the participants to identify any possible gaps. It was established that these themes were adequate to cover the breath of comments with the exception of the following additional General Questions/Comments : Why is it up to the community to find out about issues? Ongoing reporting around issues communication, how will this be done? Confidence in monitoring systems Should acts be upgraded as new technology comes along? Plans are not finished can the plant be altered in the future? Will coal seam gas be processed in the plant in the future? For just under one hour a range of issues and concerns were raised by all participants. The Chairperson facilitated some small group discussion and whole group feedback to identify and clarify the additional comments. Two EPA officers and one Esso representative assisted with noting the comments directly onto the large format prints on the walls in the meeting area (ref. section 4 of this report.) Proponent Response Following a short break a panel of representatives from both the EPA and Esso fielded initial responses to some of the issues and concerns raised from the floor. The amount of time required to work through all participants comments and concerns left an inadequate opportunity for Esso to respond to every single question identified by the participants. The Chair sought permission from all participants to extend the conference by 30 minutes to continue addressing priority concerns. In addition to the extended discussion time it was agreed that participants could the chair with further comment for consideration within one week of the conference close. Finally the panel representatives agreed to supplying a response to all questions raised post conference for inclusion in the 20B report. Please note these responses have been provided in section 4 of this report. Meeting Close The Chairperson and EPA officer Dieter Melzer thanked all participants and called the meeting to a close at 8.30pm. 8

9 4. ISSUES, CONCERNS & QUESTIONS RAISED The following notes have been collated from the comments scribed during the 20B conference and reiterated in a small amount of submissions received by the Chairperson post the conclusion of the conference. Key issues only relate to the areas where EPA have a statutory role, other concerns noted by post completion of the 20B conference have been forwarded to the EPA for their records and are not included within this summary report. Given the time constraints of the 20B conference mentioned earlier in this report the Chair sought additional responses to all questions raised from the EPA and Esso post the conference. The following table itemises the feedback received by the Chair. Where appropriate the Chair requested Esso to indicate specific elements of their works application in support of their responses. A full copy of the works application can be viewed at the following web link; Theme No. 1 Emissions Best Practice Key Issues and Comments 1. Does the plant have the capacity to process coal seam gas? 2. Leakage affecting air quality? 3. Clarification of best practice, what does this mean? 4. Who are Esso accountable to? 5. What standards are used for best practice? Comments by EPA: 1: Application is for treating gas from off-shore. 3: Best practice is a requirement of the State Environment Protection Policy (AQM). 4: Under its EPA licence and any works approval Esso is accountable to EPA. 5: Standards set in the relevant State environment protection policies are applied by EPA. This include requirements such as best practice and health design criteria for air pollutants 1. The design basis and justification for the Gas Conditioning Plant does not contemplate onshore gas extraction nor include any physical infrastructure to receive such gas. The Gas Conditioning Plant is being designed on the basis described in the Works Approval Application - to process gas received from the offshore Kipper, Tuna and Turrum fields. Any further developments will be subject to separate regulatory approvals. 2. Fugitive emissions are discussed in Section 7.1, Section A and Section E of the Works Approval Application. 3. Peter from Esso provided the following comments: Means give it your best shot by: o Looking and thinking globally 9

10 Theme Key Issues and Comments o o o Energy efficiency How to best achieve and apply solutions Appropriate technology Seek best available solution Minimise CO2 emissions Best practise is a method that has consistently shown results superior to those achieved by other means. In this case this would be achieved by applying the above. 4. Esso operates in accordance with applicable Acts and Regulations and is subject to regulatory oversight by various Government Authorities. 5. Peter from Esso provided the following comments: Best practice is judged by the various regulators External (i.e. regulatory, industry standards) where these exist Internal standards used across ExxonMobil s global operations Benchmarking of similar processes and facilities used to guide best practice during engineering design. No. 2 Management of mercury 1. What is the proposed onsite management and risk to air and water. 2. Details behind best practice for waste management? 3. What monitoring and reporting will be required? 4. What happens to the captured mercury? 5. How can EPA accept a works approval when ESSO don t know what you re doing with it (the waste)? Comments by EPA: 3: Esso s EPA licence requires a monitoring program that demonstrates compliance with the licence 4 & 5: EPA will require that mercury containing material is sent to site that is licensed by EPA to process this material containing mercury. 1. One of the principle aims of the Project is full containment of mercury through adopting appropriate technology that is readily available within industry. Information on mercury removal technology incorporated into the Gas Conditioning Plant is presented in Sections 5.2 and 5.4 of the Works Approval Application. 2. Peter from Esso provided the following comments: 2 years ago detected mercury offshore Mercury is not uncommon Mercury coming into Longford in next few years As Engineering Manager, it is my job is to understand technology and ensure 10

11 Theme Key Issues and Comments appropriate management of mercury Low concentrations Mercury adsorption technology is effectively a filtration process where mercury particles are trapped and held by filter media (not unlike a pool filter at home) Focus on containing mercury early in the process Transport and disposal is fully regulated and readily managed by experienced contractors licensed by EPA Information about environmental best practice for mercury removal is presented in Section 5.2 of the Works Approval Application. Section D of the Works Approval Application provides further information on management of mercury wastes. 3. The requirement to implement and maintain an environmental monitoring program is part of the existing Longford Plants EPA Environment Licence. A monitoring program will be developed. If the Works Approval is granted, we will then need to apply to EPA for Commissioning Approval with changes to the existing monitoring program. Section I of the Works Approval Application describes proposed changes to environmental monitoring program. 4. The mercury adsorbent shall require change-out at a frequency of approximately 3-5 years. The spent adsorbent will at all times be handled, transported and disposed of offsite by an EPA licensed and Esso approved contractor. Once the mercury is removed from the gas it will be treated and recycled for use or disposed of in accordance with EPA guidelines. 5. The spent adsorbent will at all times be handled, transported and disposed of by EPA licensed and approved contractors. Appointment of a suitable Contractor will be finalised closer to the first scheduled mercury adsorbent change-out, approximately 3-5 years after start-up of the Gas Conditioning Plant. No. 3 Noise from the plant 1. Concern around noise levels during construction of plant, how will this impact the residents? 2. Base rate noise level comparison, what is it? 3. Reading noise levels from near the houses, is this being done? 4. Country noise guidelines, what are they? 5. What happens when noise levels are exceeded? 6. What year was the noise levels data collected? Can we please have the dates for the noise modelling? 7. Why did we have the extreme vibrations over several nights in August 2012? Comments by EPA: 4: EPA has published guidelines for noise from industry in regional Victoria. These guidelines specify noise limits that are designed for quiet areas to protect sleep at residences in the regional areas 6: Noise modelling is undertaken under conditions when the noise propagation is 11

12 Theme Key Issues and Comments enhanced. These are conditions either when the wind is calm or when of light winds blow from the source towards the hearer. Noise Overview A noise study was undertaken; it demonstrated the incremental impact of the GCP will be no more than 1dB (at residences currently above the EPA Guideline). Despite significant expenditure in noise projects over the past ten years, the study did identify the existing facility is above the non-statutory EPA Guideline at some locations. This is not entirely unexpected since the existing facility has been operating since the 1960 s and the EPA Guideline was released in October 2011 We have achieved this (an incremental impact of up to 1dB for residences currently above the EPA Guideline) by adopting best practice acoustic controls in the design of the GCP, such as enclosures, silencers and lagging. The incremental impact of the GCP will continue to be managed in detailed design through a series of design targets. If the Works Approval is granted, we will apply to EPA for Commissioning Approval, a process through which we will be required to demonstrate that noise targets have been met. 1. Construction and commissioning activities will be conducted in accordance with an Environment Monitoring Plan to reduce environmental impacts so far as reasonably practicable. This is described in Section 8.4 of the Works Approval Application. 2. Section H of the Works Approval Application identifies current noise levels. 3. Section H of the Works Approval Application identifies from where noise readings were undertaken. 4. Section H of the Works Approval Application identifies the EPA Guideline, Noise from Industry in Regional Victoria. 5. If the Works Approval is granted, we will then need to apply to EPA for Commissioning Approval. Through this process Esso will be required to demonstrate that noise targets have been met and take appropriate actions as necessary to meet targets established by the regulator. 6. Section H of the Works Approval Application identifies that the noise study was completed in August/September Esso is not aware of the noise described in August No. 4 CO2 Management 1. Why does EPA fail to manage CO2 targets? 2. Carbon offset strategy equal to or better than emissions, what are the possibilities of doing this? 3. Why no carbon capture storage on site? Comments by EPA: 1: CO2 targets are not requirements under the Victorian regulatory framework. 12

13 Theme Key Issues and Comments 1. Pursuit of greenhouse gas reduction opportunities is an integral part of ongoing operations at the Longford Plants. The Longford Plants have reported Energy and Resource Efficiency Plans to the EPA since 2008, consistent with the Environment Protection (Energy and Resource Efficiency Plans) Regulations 2007 (Vic). Section A of the Works Approval Application discusses specific measures adopted by the Gas Conditioning Plant to achieve best practice levels of energy efficiency and minimise future greenhouse gas emissions. 2. Natural gas is widely seen as an important part of a lower carbon future. The Gas Conditioning Plant is part of our significant investment program in natural gas projects which will provide energy to power economic growth while also meeting a commitment to a cleaner energy future. The Gas Conditioning Plant will meet all provisions of the Federal Government s carbon tax with commencement of the Clean Energy Future Scheme. 3. Section A of the Works Approval Application discusses options considered and rejected for carbon disposal, including CCS. No. 5 Performance of existing plant 1. Communications about performance of existing plant is terrible, what is being done about this? 2. Summary of maintenance on existing plant, what reassurance can be provided? 3. Why can Esso have leaky plants when other industries conform to regulations? 1. We are currently working with neighbours to improve proactive communication. 2/3.Esso operates in accordance with applicable Acts and Regulations and the Longford Plants are a registered Major Hazard Facility (MHF) under the Occupational Health and Safety Regulations 2007 (Vic) and licensed premises under the Environment Protection Act 1970 (Vic). We have processes in place to ensure the Longford Plants are operated and maintained effectively, and these are documented in the Safety Case. This includes an extensive program of ongoing maintenance by our highly skilled workforce. The Longford Plants Safety Case is one demonstration that we are able to operate and maintain the Longford Plants safely. No. 6 Major Hazard Facility 1. Incident management plan response to community, how is this done? What are the plans? 2. Clarification on why Esso is labelled a power plant? Comments by EPA: 2: This is an error in EPA s information system and will be fixed. 1. A comprehensive Emergency Response Plan has been developed for the Longford Plants. In the event of an incident at the existing Longford Plants that may impact the 13

14 Theme Key Issues and Comments local community, we will notify the appropriate agency / emergency service. We are currently working with neighbours to improve proactive communication, and to consider the merits of alternate communication/notification methods, in the event that something unanticipated occurs at the Longford Plants. 2. Question is for EPA to answer as it related to EPA notification processes. No. 7 Air Emissions 1. What about black soot? 2. Benzene, what are the risks for leakage? 3. Isn t benzene omitted in flares? 4. How do you capture the data around benzene levels? 5. What about monitoring of benzene outside of Esso area down wind? What radius is it monitored to? 6. Does the model look at all types of gases? 7. Can we see the actual base line data collected? Comments by EPA: 3: The works approval application examines of the impact of benzene during flaring. 1. Flare systems incorporated in the Gas Conditioning Plant will be designed to operate smokelessly under routine operating conditions. Potential for emission of smoke and particulates to atmosphere as a result of process upset or non-routine operating conditions is described in Section I of the Works Approval Application. 2. Benzene is a natural component of crude oil and natural gas and we have controls in place to reduce emissions of benzene to atmosphere to the maximum extent achievable, in accordance with the State Environmental Protection Policy (Air Quality Management) Leakage hazards of natural gas, which includes Benzene (e.g. will also be considered as part of the revision to the Longford Plants Safety Case required under the Occupational Health and Safety Regulations 2007 (Vic). 3. The State Environmental Protection Policy (Air Quality Management) 2001 requires Esso to reduce emissions of benzene to atmosphere to the maximum extent achievable. Measures that the Gas Conditioning Plant will adopt to reduce benzene emissions are described in Section E of the Works Approval Application. 4. A monitoring program will be developed prior to commissioning of the Longford Gas Conditioning Plant, as outlined in Section I of the Works Approval Application. 5. Esso does not routinely conduct air emissions monitoring of the regional air-shed beyond the boundary of the Longford Plants. We routinely monitor and report discharges to air to EPA to demonstrate compliance with our Environmental Licence (EM31686). Monitoring programs may include use of additional detectors beyond the plant boundary under some circumstances. 6. No. Those emissions considered in air dispersion modelling are presented in Section E of the Works Approval Application. 7. Results of routine environmental monitoring are summarised in the publicly available 14

15 Theme Key Issues and Comments Longford Plants Annual Performance Statement, available on the EPA website. No. 8 Health Issues 1. Increased risk using back-up system in shuts, how will this be managed? 2. What about monitoring of locals health? 3. Who is the health advice from? 4. PM2.5 Black soot fine particles, what are the risks from this? Comments by EPA: 3: EPA has referred the application to the Department of Health. The department s comments are on EPA s website. 1. The Thermal Oxidiser bypass mode is detailed in Section E of the Works Approval Application. The assessment demonstrates that emissions in this mode produce ground level concentrations similar to the routine operating mode. 2. We are committed to conducting our business in a manner compatible with the environmental and economic needs of all communities in which we operates and in a way that protects the safety, health and security of employees, those involved in our operations, customers and the public. There is no evidence that the incidence of illness, including cancers, in Esso workers is higher than that in the general population. A long term HealthWatch study, conducted by Monash University, has shown that the health of workers in the petrochemical industry in Australia is better than the general population. 3. A medical doctor and an industrial hygienist provide health advice. 4. Emission of particulate matter from the combustion of gaseous hydrocarbons in well designed and effectively maintained process equipment as proposed by the Gas Conditioning Plant is considered negligible. No. 9 Age of plants (Gas Plants 1, 2 and 3) 1. Should the existing plant be reviewed first? 2. Given recent incidents what re-assurance can be offered about maintenance? Comments by EPA: 1 & 2: EPA has referred the application to Worksafe for comment. We will be seeking further comment from Worksafe that the integrity and maintenance of the plant will be managed within the Major Hazard Facility process. 1/2. Esso operates in accordance with applicable Acts and Regulations and the Longford Plants are a registered Major Hazard Facility (MHF) under the Occupational Health and Safety Regulations 2007 (Vic) and licensed premises under the 15

16 Theme Key Issues and Comments Environment Protection Act 1970 (Vic). We have processes in place to ensure the Longford Plants are operated and maintained effectively, and these are documented in the Safety Case. The Longford Plants Safety Case is one demonstration that we are able to operate and maintain the Longford Plants safely. No. 10 Advertising and process 1. Should minister for industry be consulted as to whether an EES is required or not BEFORE EPA s approval? 2. Can an EES be done by Esso independently? 3. Why the haste for the meeting? Comments by EPA: 1: The Minister for Planning has determined an EES is not required. EPA will not be asking him to review the decision. 3: EPA is required to complete its assessment within a 4 month period. It is acknowledged that due to circumstances such as holiday period(s) the time frame appears to short. 1. Esso referred the Gas Conditioning Plant to the State Minister for Planning in 2007, who subsequently determined that an Environmental Effects Statement is not required on the basis that the assessment procedures established under the Environment Protection Act 1970 (Vic) (i.e. Works Approval process) will suffice. 2. Refer above. Esso does not consider that conducting an EES would deliver any benefits over and above those addressed through the Works Approval process. 3. For EPA Response No. 11 Fire risk 1. Capacity to manage fire within Esso 2. When will Esso have its own fire fighting team? 1./2. The Longford Plants provide self-contained fire safety capability and are equipped with comprehensive fixed and mobile fire protection systems and other equipment to combat fire in any section of the plant. Most site-based employees are trained in firefighting and first aid. The Plants do not rely on outside resources during events such as threat from bushfire. The Longford Plants are a registered Major Hazard Facility (MHF) under the Occupational Health and Safety Regulations 2007 (Vic). Risks of fire (including bushfire) are assessed in the Longford Safety Case and appropriate controls have been implemented, including a comprehensive Emergency Response Plan. The Gas Conditioning Plant adds a small volume of gas to the east of the existing Longford Plants, protected by safety controls similar or higher than those provided for the existing plant. These controls, which include careful attention to site layout, are considered appropriate to avoid escalation of an incident from one gas plant to another or to surrounding areas, including native vegetation in proximity to the plant. 16

17 Theme General Questions Key Issues and Comments 1. Why is it up to the community to find out about issues? 2. Ongoing reporting around issues communication how will this be done? 3. Confidence in monitoring systems 4. Should acts be upgraded as new technology comes along? 5. Plans are not finished can the plant be altered in the future? 6. Will coal seam gas be processed in the plant in the future? 1/2. We are currently working with neighbours to improve proactive communication. 3. Environmental monitoring for the existing Longford Plants is undertaken in accordance with an EPA approved Environmental Monitoring Plan. Changes resulting from the introduction of the Gas Conditioning Plant will be incorporated into this Plan, as presented in Section I of the Works approval Application. 4. EPA Standards have changed. 5. Modifications to the Plant will comply with all applicable Acts and Regulations. Environmental impacts will be subject to assessment procedures established under the Environment Protection Act 1970 (Vic). 6. The design basis and justification for the Gas Conditioning Plant does not contemplate onshore gas extraction nor include any physical infrastructure to receive such gas. The Gas Conditioning Plant is being designed on the basis described in the Works Approval Application - to process gas received from the offshore Kipper, Tuna and Turrum fields. Any further developments will be subject to separate regulatory approvals. 17

18 5.0 Participant Feedback The following is a summary of the feedback received from participants in relation to the conference from an exit poll vote. Question no. 1: Did you feel that your concerns and issues were understood 10 = very understood, 1 = not understood Scores: Number of dots: Approx. 7 to 10 8 Around 5 8 Less than 5 2 Negative 4 N = 22 Question no. 2: Did you feel comfortable and able to participate 10 = very understood, 1 = not understood Scores: Number of dots: Approx. 7 to Around 5 2 Less than 5 0 Negative 4 N = 22 18

19 Chairman s Conclusions and Recommendations The purpose of this 20B Conference report is intended to accurately record feedback from the community to inform EPA officers currently reviewing the final decision around the works application. The following observations and recommendations represent the Chair s closing comments based on the stated objectives of the forum: 1. For the EPA and Conference Chair to have and understanding of community concerns and issues with the proposal. Comment: Participants raised a considerable amount of questions and comments in relation to the works application. With the exception of approximately half a dozen general points the summary themes extracted from the 50 formal submissions appear to represent a reasonable summary of the collective concerns and issues that relate specifically to this works application. The proponent demonstrated a commitment to having a broad range of both project and operational personnel present at the 20B conference and further supported an attempt to address specific questions with post conference comments supplied in section 4 of this report. The community appeared to have had limited opportunity to build ongoing relationships with the proponent with previous interactions being limited to specific, sometimes isolated events. While all participants demonstrated an intent to work collaboratively at the conference there was a clear level of anxiety around trust in the proponents observations and comments. Recommendation: That the proponent follows through on comments made during the 20B conference and in the comments collated in this report to determine how best to engage with its community for the long term. Any such considerations would be well placed to consider best practice values models promoted by associations such as the International Association of Public Participation. Any such planning should specifically involve community representatives in discussing how best to resolve this concern and establish ongoing review processes. Timing and regularity for these processes should be carefully considered in order to foster stronger long term relationships between the proponent and its community. 2. To clarify process, procedures & timelines involved for EPA decision making. Comment: Recommendation: There was clear dissatisfaction in relation to the timing of the 20B conference and the short, less than one weeks, final invite notice for the 20B conference date. In support of this concern the EPA did acknowledge the conflict between school holidays and their legal time constraints to complete the process. EPA to consider how the likely impact on any 20B conference process when works applications are received in late December of any calendar year so as to minimise any such reoccurrences. 19

20 3. To identify potential options for EPA and the applicant to consider to address community concerns and issues with the proposal. Comment: Throughout the panel question and answer process participants circled back to concerns around the safety and current operations of the facility. It was recognised that this fell outside of the works approval process but did impact on nearly all points raised during the conference. These concerns were compounded by a number of previous incidents being reference by some participants. The current labeling of the facility as a power plant was acknowledged by all as being inaccurate and potentially misleading. A modest amount of discussion time was allocated to one of the issues, the disposal of mercury. It was clear that this would require more understanding about operational issues and disposal practices. Recommendation: EPA to ensure the current referral to Worksafe is followed up and a detailed response is shared via the EPA s website where possible. EPA works to modify the current labeling of the facility as a priority for the area but within the parameters set by the GIS map information drawn from VicMap. This may require a referral from EPA to have this changed first. Pending the works approval and planning permit outcomes the proponent should seek to meet with community representatives in the detailing of plans for disposal of mercury from the new facility. 20

21 Appendix 1: Summary of questions raised by participants at the 20B in response to the EPA summary concerns relating to WA70863 Theme No. 1 Emissions Best Practice No. 2 Management of mercury No. 3 Noise from the plant No. 4 CO2 Management No. 5 Performance of existing plant Key Issues and Comments 1. Does the plant have the capacity to process coal seam gas? 2. Leakage affecting air quality? 3. Clarification of best practice, what does this mean? 4. Who are Esso accountable to? 5. What standards are used for best practice? 1. What is the proposed onsite management and risk to air and water. 2. Details behind best practice for waste management? 3. What monitoring and reporting will be required? 4. What happens to the captured mercury? 5. How can EPA accept a works approval when ESSO don t know what you re doing with it (the waste)? 1. Concern around noise levels during construction of plant, how will this impact the residents? 2. Base rate noise level comparison, what is it? 3. Reading noise levels from near the houses, is this being done? 4. Country noise guidelines, what are they? 5. What happens when noise levels are exceeded? 6. What year was the noise levels data collected? Can we please have the dates for the noise modelling? 7. Why did we have the extreme vibrations over several nights in August 2012? 1. Why does EPA fail to manage CO2 targets? 2. Carbon offset strategy equal to or better than emissions, what are the possibilities of doing this? 3. Why no carbon capture storage on site? 1. Communications about performance of existing plant is terrible, what is being done about this? 2. Summary of maintenance on existing plant, what reassurance can be provided? 3. Why can Esso have leaky plants when other industries conform to regulations? 21

22 Theme No. 6 Major Hazard Facility No. 7 Air Emissions No. 8 Health Issues No. 9 Age of plants (Gas Plants 1, 2 and 3) No. 10 Advertising and process No. 11 Fire risk General Questions Key Issues and Comments 1. Incident management plan response to community, how is this done? What are the plans? 2. Clarification on why Esso is labelled a power plant? 1. What about black soot? 2. Benzene, what are the risks for leakage? 3. Isn t benzene omitted in flares? 4. How do you capture the data around benzene levels? 5. What about monitoring of benzene outside of Esso area down wind? What radius is it monitored to? 6. Does the model look at all types of gases? 7. Can we see the actual base line data collected? 1. Increased risk using back-up system in shuts, how will this be managed? 2. What about monitoring of locals health? 3. Who is the health advice from? 4. PM2.5 Black soot fine particles, what are the risks from this? 1. Should the existing plant be reviewed first? 2. Given recent incidents what re-assurance can be offered about maintenance? 1. Should minister for industry be consulted as to whether an EES is required or not BEFORE EPA s approval? 2. Can an EES be done by Esso independently? 3. Why the haste for the meeting? 1. Capacity to manage fire within Esso 2. When will Esso have its own fire fighting team? 1. Why is it up to the community to find out about issues? 2. Ongoing reporting around issues communication how will this be done? 3. Confidence in monitoring systems 4. Should acts be upgraded as new technology comes along? 5. Plans are not finished can the plant be altered in the future? 6. Will coal seam gas be processed in the plant in the future? 22