works approval supporting documentation for … · 1 10-12-2019 final rev1 k barker r t benbow...

Engineering a Sustainable Future for Our Environment

Head Office: 25-27 Sherwood Street, Northmead NSW 2152 AUSTRALIA

Tel: 61 2 9896 0399 Fax: 61 2 9896 0544

Email: [email protected]

Visit our website: www.benbowenviro.com.au

WORKS APPROVAL

SUPPORTING DOCUMENTATION FOR STERITECH PTY LTD

160 SOUTH GIPPSLAND HWY, DANDENONG

Prepared for: Steritech Pty Ltd

EPA Victoria

Prepared by: Linda Zanotto, Senior Environmental Engineer

R T Benbow, Principal Consultant

Report No: 181187-02_Final Works Approval Supporting Documentation

March 2020

(Released: 10 March 2020)

COPYRIGHT PERMISSION

The copyright for this report and accompanying notes is held by Benbow Environmental. Where

relevant, the reader shall give acknowledgement of the source in reference to the material

contained therein, and shall not reproduce, modify or supply (by sale or otherwise) any portion of

this report without specific written permission. Any use made of such material without the prior

written permission of Benbow Environmental will constitute an infringement of the rights of

Benbow Environmental which reserves all legal rights and remedies in respect of any such

infringement.

Benbow Environmental reserves all legal rights and remedies in relation to any infringement of its

rights in respect of its confidential information.

Benbow Environmental will permit this document to be copied in its entirety, or part thereof, for

the sole use of the management and staff of Steritech Pty Ltd.

DOCUMENT CONTROL

Prepared by: Position: Signature: Date:

Linda Zanotto Senior Environmental

Engineer

10 March 2020

Reviewed by: Position: Signature: Date:

Kate Barker Environmental

Scientist

10 March 2020

Approved by: Position: Signature: Date:

R T Benbow Principal Consultant

10 March 2020

DOCUMENT REVISION RECORD

Revision Date Description Checked Approved

1 10-12-2019 Final Rev1 K Barker R T Benbow

DOCUMENT DISTRIBUTION

Revision Issue Date Issued To Issued By

1 10-12-2019 Steritech Pty Ltd Benbow Environmental

Contents Page

SECTION 1 - GENERAL INFORMATION 3

1. Primary Information 3

1.1 Company Legal Entity 3

1.2 Application Fee 3

2. Land Use 3

2.1 Planning and other approvals 3

2.2 Choice of location for new premises 3

3. Track Record 4

4. Process and Integrated Environmental Assessment 5

4.1 Existing Operation 5

4.2 Description of the Proposal 6

4.3 Process and Technology 8

4.4 Environmental best practice 9

4.5 Choice of Process and Technology 10

4.6 Integrated Environmental Assessment 11

SECTION 2 - ENVIRONMENTAL INFORMATION 12

5. Energy Use and Greenhouse Gas Emissions 12

5.1 General Information 12

6. Water Use 12

6.1 General Information 12

7. Air Emissions 12

7.1 Air Emissions Assessment 12

8. Noise Emissions 13

8.1 General Noise Impact Assessment 13

9. Water 13

10. Land & Groundwater 13

11. Waste 14

11.1 Industrial Waste Generation 14

12. Environmental Management 14

12.1 Risk assessment of non-routine operations 14

12.2 Management System 14

12.3 Construction Impact Management 14

SECTION 3 – OTHER APPROVALS 15

13. Seeking Other EPA Approvals 15

13.1 Commissioning Plan 15

13.2 New Licence or Licence Amendment Subsequent to Works Approvals 15

14. Post Decision – Operational Requirements 15

14.1 Financial assurance 15

14.2 Polychlorinated Biphenyls (PCBs) Management 15

14.3 Monitoring 15

14.4 Reporting annual performance 16

LIMITATIONS 17

Tables Page

Table 0-1: Nearest Potentially Affected Receptors 6

Table 6-1: General Information (<10 TJ/yr) 12

Table 8-2: Comparison between predicted ground level concentrations (GLCs) of emitted

pollutants and design criteria (Schedule A) of SEPP (AQM) 13

Table 12-3: Estimated future industrial waste generation 14

Table 14-1: Proposed Licence Limits for Air Emissions 15

Table 15-2: Design performance of pollution control equipment 16

Figures Page

Figure 0-1: Location of Subject Site 4

Figure 0-2: Location of nearest sensitive receptors 8

Figure 0-3: Catalytic Abatement Plant Process Diagram provided by Lesni 9

Attachments

Attachment 1: Company Legal Entity

Attachment 2: Site Layout Plan

Attachment 3: Air Quality Impact Assessment

Attachment 4: Environmental Management Plan

Attachment 5: Manufacturer’s Description and Performance Guarantee

Steritech Pty Ltd

Works Approval Supporting Documentation

Ref: 181187-02_FINAL WORKS APPROVAL SUPPORTING DOCUMENTATION Benbow Environmental

March 2020 Page: 3

SECTION 1 - GENERAL INFORMATION

1. PRIMARY INFORMATION

1.1 Company Legal Entity

The completed company legal entity form is provided as Attachment 1.

1.2 Application Fee

The application fee is the greater of:

1 percent of the estimated cost = 1% x $1,000,000 = $10,000

81.83 fee units (1 fee unit is $14.81 for the 2019-20 financial year) = 81.83 x $14.81 =

$1,212.00

Note: The maximum fee payable is 4,500 fee units ($66,645).

Therefore, the application fee is $10,000 + GST.

2. LAND USE

2.1 Planning and other approvals

A planning permit is required for the installation of the Catalytic Abatement Plant to treat

emissions of ethylene oxide from the existing facility. The planning permit application is being

submitted in conjunction with the works approval application.

2.2 Choice of location for new premises

Steritech already operate the sterilisation facility at the subject site and the land is located at 160

South Gippsland Highway, Dandenong South VIC 3175, and is legally described as Lot 1 TP

921633. The location of the site as shown in Figure 0-1.

The proposed development is for the replacement of existing air pollution control equipment.

Existing flares used for the destruction of ethylene oxide emissions would be replaced by a

catalytic abatement plant. Therefore, key factors for selecting the site do not need to be

provided.

Steritech Pty Ltd



March 2020 Page: 4

Figure 0-1: Location of Subject Site

Source: Google Maps 2019

Legend: Site boundaries

Benbow Environmental 25-27 Sherwood Street, Northmead NSW 2152

3. TRACK RECORD

In the past three years, Steritech Pty Ltd has received:

No community complaints or concerns;

No enforcement actions from EPA including written warnings, penalty infringements or

prosecutions.

In the past 10 years, Steritech (including directors and persons involved in the management of

the corporation) has not been found guilty of an offence under the Environment Protection Act,

1970, Dangerous Goods Act, 1985, Occupational Health and Safety Act, 2004 or the Equipment

(Public Safety) Act, 1994, nor committed any offence committed outside Victoria.

Steritech Pty Ltd



March 2020 Page: 5

4. PROCESS AND INTEGRATED ENVIRONMENTAL ASSESSMENT

4.1 Existing Operation

The main site activity is the sterilisation of medical and quarantine products. The sterilisation

process uses ethylene oxide gas to infiltrate the products and packaging in order to kill

micro-organisms by exposing them to the gas under a vacuum in a sealed chamber. Ethylene

oxide (EtO) is an extremely effective sterilising agent for this purpose due to its strong alkylating

properties: it attacks the cellular proteins and nucleic acids of the target micro-organisms,

bringing cell reproduction to a halt and ensuring cell death.

The process of sterilisation with EtO is a three-stage process involving preconditioning,

sterilisation and aeration. In addition to product sterilisation, there is the essential step of air

purification (i.e. control and destruction of EtO before releasing air emissions from the facility).

Steritech Pty Ltd



March 2020 Page: 6

4.2 Description of the Proposal

Steritech propose to establish new air pollution control equipment for the destruction of

ethylene oxide from their existing sterilisation facility. The existing facility includes two

sterilisation plants, each with its own flare and vertical aeration stack. The new air pollution

control equipment proposed to be installed is a catalytic abatement plant (CAP) that would

replace the flares currently in use for the destruction of ethylene oxide.

The proposal is being pursued on the basis of environmental considerations as a result of an

industrial best practice review of environmental emissions technologies undertaken by Steritech,

with the CAP being found to be the best in terms of destruction efficiency and meeting design

criteria for ethylene oxide. In addition, the flares rely on the consumption of large amounts of

natural gas, which results in higher running costs and a larger carbon footprint compared to

those of the CAP.

Overall, the existing development would not change significantly as a result of the proposal, as

most of the facility’s processes would remain unvaried with the exception of the method of air

pollution control for EtO emissions. Site operations, hours of operation, annual capacity and

employment numbers would remain the same.

Current hours of operation are 24/7. This will not change.

Waste generated by the CAP would include 12,000 Litres of liquid waste from the balancer tank

requiring clean out yearly by a licensed waste contractor. The inactive catalyst (a non-dangerous

good) would require replacing every 5 to 10 years. Waste management is detailed in Section 11.

The nearest sensitive receptors are identified in the table and figure below. The nearest

residential area is 1.59 km to the north-east of the site there are also residential areas 2 km to

the north-west and 2 km to the south-east. The nearest waterway is Eumemmerring Creek, 260

m east of the site.

Table 0-1: Nearest Potentially Affected Receptors

Receptor ID Lot & DP Address Separation

distance Type of receiver

R1 3 PS717564 3/6 Culliver Avenue,

Eumemmerring

1,560 m NE Residential

R2 1 LP23829 2 Olive Road,

Eumemmerring

1,780 m NE Residential

R3 37 LP58583 2 Kays Avenue, Hallam 2,240 m ENE Residential

R4 743 LP201041 4 Affra Place,

Hampton Park

1,930 m ESE Residential

R5 729 LP135000 140 Oaktree Drive,

Hampton Park

2,000 m SE Residential

R6 1 RP14392 1/2 Robjant Street,

Hampton Park

1,960 m SE Residential

R7 9 LP127254 31 Vivien Street,

Dandenong

2,080 m NW Residential

Steritech Pty Ltd



March 2020 Page: 7

Table 0-1: Nearest Potentially Affected Receptors

Receptor ID Lot & DP Address Separation

distance Type of receiver

R8 20 LP53275 19 Trewin Street,

Dandenong

2,020 m NW Residential

R9 8 LP41759 22 Kirkham Road,

Dandenong

2,000 m NNW Residential

R10 531 LP57859 7 Claredale Road,

Doveton

1,830 m N Residential

R11 7 LP5857 41 Wattle Drive,

Doveton

1,810 m NNE Residential

R12 1 PS437402 22 Power Road,

Doveton

1,840 m NNE Residential

R13 2 PS42760 152-158 South

Gippsland Highway,

Dandenong South

Adjacent N Industrial

Clark’s

Equipment Sales

R14 1 TP174481 170 South Gippsland

Highway, Dandenong

South

Adjacent S Industrial

Tip Top Bakery

R15 1 TP584435 1-9 Hedderwick Road,

Dandenong South

250 m E Industrial

Solos Glass

R16 2 PS443295 95 Greens Road,

Dandenong South

400 m W Industrial

Oceania Glass

R17 1 TP431340 115 S Gippsland Hwy,

Dandenong

380 m NE Commercial

Lunar Drive-In

Movie Theatre

and

Trash &

Treasure Market

R18 2 LP124961 2-4 Round Tower

Road, Dandenong

450 m SE Billiard Halls

R19 1 TP954394 99 Greens Road,

Dandenong South

15 m W Cranbourne Line

proposed raised

rail line

Steritech Pty Ltd



March 2020 Page: 8

Figure 0-2: Location of nearest sensitive receptors

LEGEND:

Site

Receptor +

Benbow Environmental 25-27 Sherwood Street, Northmead NSW 2152

A site plan is provided as Attachment 2.

4.3 Process and Technology

A Catalytic Abatement Plant (CAP) is proposed to be installed at the Steritech facility in order to

purify exhaust air from the sterilisation and heated aeration chambers. The CAP effectively

converts EtO into carbon dioxide and water vapour, which would be released from a single stack.

The manufacturer of the abatement plant (Lesni) guarantees that the trace concentrations of EtO

in the stack’s exhaust air will meet current European standards (TA-Luft), which demand EtO

emissions of less than 0.5 mg/m3 or less than 0.28 ppm.

The CAP proposed to be installed functions on a two-step system – a balancer tank and catalytic

abator (depicted in Figure 0-3), without the need for using sulphuric acid and without the

generation of glycol waste, unlike other technologies used in the sterilisation industry.

The balancer tank and catalytic abator are designed to operate continuously, for 24 hours a day,

for every day of the year, and can be sized to handle different gas evacuation quantities. The CAP

R19+

Steritech Pty Ltd



March 2020 Page: 9

to be installed would be designed to cater for the existing two sterilisation chambers and two

heated aeration rooms used at the Steritech facility.

The system is constructed with an efficient heat exchanger, integrated to recover energy from

the exothermic reaction of the EtO destruction process.

Manufacturer description has been provided as Attachment 5.

Figure 0-3: Catalytic Abatement Plant Process Diagram provided by Lesni

4.4 Environmental best practice

An industrial best practice review of environmental emissions technologies was undertaken by

Steritech in 2015 when considering options for the Sydney facility. The CAP was found to be the

best in terms of destruction efficiency and meeting design criteria for ethylene oxide. Ground

level concentrations of ethylene oxide at nearest receptors using the existing flares and the CAP

have been determined in the AQIA in Attachment 3 to demonstrate potential improvements in

air quality.

Furthermore, the existing flares rely on the consumption of large amounts of natural gas, which

results in higher running costs and a larger carbon footprint compared to those of the CAP.

Steritech Pty Ltd



March 2020 Page: 10

4.5 Choice of Process and Technology

In 2015, an Ethylene Oxide Air Controls Study was undertaken for Steritech’s NSW facility. The

purpose of this study was to determine the suitability of alternate ethylene oxide control

technologies for the site with regard to air quality issues. The report presented the following:

Review of world’s best practice control technologies for ethylene oxide in sterilisation

chamber exhaust gas;

Greenhouse gas assessment of proposed air cleaning systems;

Air pollution modelling to predict the ground level ethylene oxide contribution from site

operations with various proposed control systems in place.

A literature review of world’s best practice control technologies found that information on best

practice for the destruction of EtO after the sterilisation process is not readily available, most

likely due to this being a specialised process. The control technologies available and currently

being used at sterilisation facilities around the world, their advantages and disadvantages and

examples were evaluated with the following found to be the preferred method of control for EtO

destruction:

Acid-catalysed scrubber/wet scrubber;

Catalytic converter (catalytic oxidiser and water balance); and

Solid reactant bed filter and wet scrubber.

The total amount of greenhouse gas emissions from a scrubber is approximately 250 tonnes per

annum; from a catalytic converter is approximately 1700 tonnes per year; and the total amount

from a thermal oxidiser is 3000 tonnes per year. The carbon footprint of a scrubber is much less

than that of a thermal oxidiser and is the best choice with respect to reduction in carbon

emissions. A catalytic converter is also significantly better than a thermal oxidiser, reducing the

carbon emissions by over 40%.

Air modelling was undertaken using AERMOD in accordance with the NSW EPA guidelines

“Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales”,

August 2005 (AMMAAP). The modelling determined the predicted ground level ethylene oxide

contribution from site operations with the various proposed control systems.

The study considered three alternate air cleaning systems; a Bete make scrubber, a Sterimed

scrubber and filter and a Sterimed catalytic converter.

Fifteen (15) scenarios were modelled with systems assumed to be operating under worst case

conditions. Compliance with the Clean Air Regulations and AMMAAP criteria was achieved for all

scenarios with greater efficiency than 99.99%. AMMAAP criteria can be achieved at lower

efficiencies where the stack height is increased.

From this, Steritech originally proposed to switch from the thermal oxidisers to a three stage

scrubber system with a filter. The manufacturer of this system can provide a performance

guarantee of 99.99%. Test data supplied by the system manufacturer demonstrates compliance

with the 99.9999% destruction efficiency criteria and the AMMAAP ground level concentration

criteria but with no guarantee of this performance from the manufacturer in Australia.

Steritech Pty Ltd



March 2020 Page: 11

Since then, Steritech reviewed this choice and has obtained approval from Fairfield City Council

and NSW EPA for installation of a Catalytic converter (also called Catalytic Abatement System) at

their Wetherill Park facility for which the manufacturer Lesni can provide a guarantee that EtO

stack emissions will be less than 0.5 mg/m3 (0.28 ppm) which would achieve 99.9999%

destruction efficiency.

4.6 Integrated Environmental Assessment

The impacts on air quality including emissions of ethylene oxide and greenhouse gas emissions

were by far the most significant aspect of the change to pollution control equipment that needed

to be assessed. Noise, waste and water and other environmental aspects were also considered

and assessed to ensure that any potential impacts could be mitigated.

Steritech Pty Ltd



March 2020 Page: 12

SECTION 2 - ENVIRONMENTAL INFORMATION

5. ENERGY USE AND GREENHOUSE GAS EMISSIONS

5.1 General Information

The overall level of energy use and energy-related GHG emissions associated with current and

proposed works are provided in the following table. The information provided compares the

existing pollution control equipment with the proposed CAP. All other energy requirements

associated with the operation of the facility will remain the same, the total energy requirements

will be <10TJ/year.

Table 5-1: General Information (<10 TJ/yr)

Works Total annual energy use

TJ/yr

Total energy-related

GHG emissions

tCO2-e/yr

Use of flares (Current) 1.945 TJ 107.8

Use of CAP (Proposed) 1.621 TJ 89.9

There are no non-energy related GHG emissions associated with the proposal.

6. WATER USE

6.1 General Information

The proposed works would result in water usage to remain at <10 ML/yr for the facility.

The current water usage is: 1.8 ML/yr.

7. AIR EMISSIONS

7.1 Air Emissions Assessment

An Air Quality Impact Assessment (AQIA) has been prepared and is provided in Attachment 3.

The following tables below provide a summary.

Model used AERMOD

Met file used A five year (2013-2017) no observation prognostic meteorological data file

was created by Lakes Environmental using the WRF-MMIF model.

Steritech Pty Ltd



March 2020 Page: 13

Table 7-2: Comparison between predicted ground level concentrations (GLCs) of emitted

pollutants and design criteria (Schedule A) of SEPP (AQM)

Indicator

Predicted

maximum GLC

(projected)

(mg/m3)

Background

concentration

(mg/m3)1

Predicted

maximum GLCs

(total)

(mg/m3)

Design criteria

(mg/m3)

Ethylene oxide 0.0021 0 0.0021 0.006 1. There are no known EtO generators in the surrounding industrial area to the site. Therefore background

concentrations of EtO can be assumed to be negligible.

8. NOISE EMISSIONS

8.1 General Noise Impact Assessment

The proposed works would not result in an emission of audible noise at the nearest noise

sensitive receptors and there would be no noticeable change in existing emissions from the

facility as it is expected that new pollution control equipment will operate at a similar noise level

to existing equipment. Therefore, a general noise impact assessment has been provided with the

Noise Management Plan which is included as a sub-plan of the site’s Environmental Management

Plan in Attachment 4.

9. WATER

The proposed works would not result in generation of contaminated stormwater.

The premises will not process waste or generate leachate.

The premises will not be scheduled under the Scheduled Premises Regulations as Sewage

Treatment and does not involve operating a wastewater treatment system.

The proposed works does not intend to discharge contaminated stormwater, process wastewater

or treated wastewater to surface water.

10. LAND & GROUNDWATER

The existing and proposed works does not involve any of the following:

Underground storage of petroleum

Pipeline transfer of petroleum

Groundwater extraction

Injection of waste to groundwater

The existing and proposed will not reuse treated wastewater on land.

Steritech Pty Ltd



March 2020 Page: 14

11. WASTE

11.1 Industrial Waste Generation

The existing and proposed works would generate less than 1,000 tonnes per year of industrial

wastes.

12.1.1 General Information

A waste management plan is provided as sub-plan 2 in the EMP (Attachment 4). A summary of

waste that would be generated by the CAP is provided in the following table.

Table 11-3: Estimated future industrial waste generation

Type of waste generated Volume Disposal destination

Inactive catalysts material

(From the catalyst chamber in the

proposed CAP. Minimum expected

lifetime of catalyst is 5 years.)

2 T

Once every 5-

10 years

Disposed offsite

Inactive catalyst will be collected in

original receptacle and disposed

offsite to a licensed waste facility

(landfill). The waste is classed as

non-hazardous.

CAP process water – liquid waste

(From the Balancer tank of the CAP.)

Up to 12,000 L

Once yearly

max

Disposed offsite

The process water in the balancer

tank is constantly reused in a closed

loop, but requires replacement once

every year or less. Wastewater will

be collected by a licensed waste

contractor for treatment off site.

12. ENVIRONMENTAL MANAGEMENT

12.1 Risk assessment of non-routine operations

Under upset or non-routine operation conditions there is potential for escape of ethylene oxide

that could cause environmental impacts. A Pollution Incident Response Management Plan

(PIRMP) for the facility has been prepared that explains the risks and precaution measures used

to prevent and minimise environmental impacts. The PIRMP is provided as sub-plan B3 in the

EMP (Attachment 4).

12.2 Management System

The Environmental Management Plan for the facility is provided as Attachment 4.

12.3 Construction Impact Management

The construction activities include installation of the pre-fabricated system on the existing

hardstand area at the site. These activities would not cause significant environmental impacts

such as dust, noise or discharge of contaminated stormwater.

Steritech Pty Ltd



March 2020 Page: 15

SECTION 3 – OTHER APPROVALS

13. SEEKING OTHER EPA APPROVALS

13.1 Commissioning Plan

Steritech may require commissioning approval under Section 30A of the EP Act and wish to

include the commissioning approval in this application. Steritech understand that upon

completion of works when ready to operated, EPA will be notified and provided with a

commissioning plan that will include:

A timeline

Details of process commissioning (including sequence and test conditions)

Critical control points and the environmental risks

Performance testing (including parameters to be monitored, frequency and reporting).

13.2 New Licence or Licence Amendment Subsequent to Works Approvals

A new licence is required under the Scheduled Premises Regulations. The operations includes air

discharges and proposed limits are detailed below.

Table 13-1: Proposed Licence Limits for Air Emissions

Description of

discharge point

Stack height

(metres)

Emission

indicator

Licence Limit (mg/min) Schedule D or

E of SEPP

(AQM) Existing

(if applicable) Proposed

CAP Stack 10 metres Ethylene

Oxide N/A 83.4 Not listed

The operations will not result in water discharges.

14. POST DECISION – OPERATIONAL REQUIREMENTS

14.1 Financial assurance

The premises is specified under L01 of the Scheduled Premises Regulations and therefore

financial assurance is not required.

14.2 Polychlorinated Biphenyls (PCBs) Management

Not applicable.

14.3 Monitoring

A monitoring program will be prepared for emissions of ethylene oxide as required under the

licence.

Steritech Pty Ltd



March 2020 Page: 16

14.4 Reporting annual performance

Steritech acknowledge that they will be required to submit an online annual performance

statement with reference to EPA publications 1320 and 1322.

The Pollution equipment manufacturers’ performance guarantees are provided as Attachment 5.

The following table provides the design performance of the proposed pollution control

equipment.

Table 14-2: Design performance of pollution control equipment

Yes Emission indicator Duration

Air emission control equipment X Ethylene oxide 24/7

Noise emission control equipment N/A

Wastewater treatment equipment N/A

Other (please specify): N/A

This concludes the report.

Linda Zanotto

Senior Environmental Engineer

R T Benbow

Principal Consultant

Steritech Pty Ltd



March 2020 Page: 17

LIMITATIONS

Our services for this project are carried out in accordance with our current professional standards

for site assessment investigations. No guarantees are either expressed or implied.

This report has been prepared solely for the use of Steritech Pty Ltd, as per our agreement for

providing environmental services. Only Steritech Pty Ltd is entitled to rely upon the findings in

the report within the scope of work described in this report. Otherwise, no responsibility is

accepted for the use of any part of the report by another in any other context or for any other

purpose.

Although all due care has been taken in the preparation of this study, no warranty is given, nor

liability accepted (except that otherwise required by law) in relation to any of the information

contained within this document. We accept no responsibility for the accuracy of any data or

information provided to us by Steritech Pty Ltd for the purposes of preparing this report.

Any opinions and judgements expressed herein, which are based on our understanding and

interpretation of current regulatory standards, should not be construed as legal advice.

ATTACHMENTS

Attachment 1: Company Legal Entity

Attachment 2: Site Layout Plan

Attachment 3: Air Quality Impact Assessment

Attachment 4: Environmental Management Plan

Attachment 5: Manufacturer’s Description and Performance Guarantee

works approval supporting documentation for … · 1 10-12-2019 final rev1 k barker r t benbow...

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