2011 industry audit program – targeting industries that pose a high risk of environmental harm

On 12 September 2011 the NSW Government commenced a major program of regulatory initiatives in response to the Orica incident in Koorangang Island. As part of this program the EPA conducted an audit program targeting industries across NSW that pose a high risk of environmental harm.

The EPA audited 40 premises that pose a high environmental risk in NSW and included facilities that store toxic, hazardous or dangerous substances in large quantities or volumes; including oil refineries, chemical processing plants, large chemical and gas storage depots and large chemical warehouses. These industries, largely located in the Sydney, Newcastle and Wollongong regions, have a potential for high environmental harm if appropriate controls are not in place to manage the risks.

The audit program focused on the management of potential risks to human health and the environment by these premises, and the adequacy of emergency response procedures for managing major environmental incidents.

This is about making sure that industries that pose a high risk to the environment have controls in place to manage major risks and have appropriate emergency response and reporting procedures to respond if these controls fail.

The summary report Management of Environmental Risks and Emergencies: Compliance Audit Program (PDF 218KB) is available.

Questions and answers

Who was audited?

The EPA audited facilities that store, handle or process very hazardous, toxic or dangerous chemicals in large quantities or volumes and are generally located in residential areas and/or near sensitive receiving environments. The audit program focused on the management of potential risks to human health and the environment by these premises, and the adequacy of emergency response procedures for managing major environmental incidents.

In total 40 premises were audited by the EPA - 34 premises regulated by the EPA, and another six premises regulated by the councils.

  • 26 in the Sydney region
  • 7 in the Hunter region
  • 2 in the Illawarra region
  • 5 in regional NSW

When were the audits completed?

All audit inspections were completed by mid December 2011 and all audit reports have been finalised.

How did you decide who should be audited?

The audit targeted industries that pose a high risk of environmental harm through chemical production and storage, petroleum and fuel production, bulk shipping, dangerous goods production, waste storage and metallurgical activities.

A further consideration was the proximity of any company to local communities.

What were the findings of the audit?

The EPA found that most of the facilities audited had appropriate systems in place to manage environmental risks and respond to emergencies. However there were a number of areas that needed attention or improvement, including:

  • appropriate environmental controls in place to minimise air and water impacts 
  • regular monitoring and testing of the effectiveness of any environmental controls
  • stormwater management
  • up-to-date emergency response plans
  • providing timely written reports to the EPA and
  • advertising the public complaints line as a ‘complaints line’.

What action has the EPA taken?

The audit identified 62 non-compliances (15 for council regulated premises) and 14 of them were considered serious or ‘high risk’ (two for council regulated premises).

The high risk non-compliances included hazardous chemicals being stored without adequate containment, a valve installed to prevent contaminated water entering stormwater not operating properly, and an emergency response plan not having clear procedures in the case of an emergency.

The EPA and councils took action against every non-compliance identified as part of the audit. To date the majority of issues have been rectified.

Did the EPA issue any penalty infringement notices to any of the facilities audited?

The EPA took strong regulatory action against the most serious offences, including issuing:

  • eight prevention notices
  • four penalty notices
  • two legal binding pollution reduction programs and
  • 16 warning letters.

Who carried out the audits?

The audits were carried out by trained EPA officers and council officers, and included accredited auditors.

What did the on site audits involve?

The EPA team of auditors and council officers inspected the facilities and focused on their management of potential environmental risks and the adequacy of emergency response procedures for managing major environmental pollution incidents.

Why were facilities given prior warning of the EPA inspections?

All of the companies audited were advised that EPA was undertaking an audit program, but they were not advised of the actual day of the audit inspections. Prior notification was given as the EPA required facilities to provide details of potential risks and their emergency response plans before the audits commenced so that the audits could focus on priority environmental issues.

Is the EPA planning any further audits?

The EPA will be conducting a further audit program on licensees’ compliance with the new requirements to prepare pollution incident management response plans. Licensees need to have these plans in place by 1 September 2012.

The EPA will also continue to conduct compliance and enforcement activities to ensure facilities are complying with licence requirements and the issues identified by the audits do not re-occur.

Why wasn’t an audit of Orica, Kooragang Island undertaken?

Following the 8 August 2011 incident, the EPA required Orica to undertake a comprehensive mandatory audit of its Kooragang Island premises. The audit is being conducted by an independent audit team who have been approved by the EPA. The audit is systematically assessing the plant’s operational practices and procedures to ensure that it operates in an environmentally satisfactory manner. The audit will also provide advice on any improvements that can be made. An audit of the ammonia plant is currently being conducted with a report to be provided to the EPA by 1 July 2012.

Audited EPA regulated premises

Licence number Accountable party Location Link to PDF
11690 AUSTRALIAN PETRO CHEMICAL STORAGE PTY LTD Ingleburn 120333AuditAusPetroChem.pdf (200KB)
6092 BLUESCOPE STEEL (AIS) PTY. LTD. Port Kembla 120330AuditBluescope.pdf (840KB)
10095 BOC LIMITED Cringila 120327AuditBOC.pdf (408KB)
13141 BOC LIMITED Wagga Wagga 120332AuditBOCWagga.pdf (193KB)
6679 BOC LIMITED Wetherill Park 120331AuditBOCSydney.pdf (199KB)
837 CALTEX REFINERIES (NSW) PTY LTD Kurnell 120300AuditCaltex.pdf (221KB)
12259 COREGAS PTY LTD Yennora 120328AuditCoregas.pdf (234KB)
4458 DEGREMONT PTY LIMITED Wetherill Park 120302AuditProspect.pdf (698KB)
12325 DOWNER EDI MINING - BLASTING SERVICES PTY LTD Singleton 120301AuditDowner.pdf (135KB)
12158 DYNO NOBEL ASIA PACIFIC PTY LIMITED Warkworth 120307AuditDyno.pdf (143KB)
10698 ELGAS LTD Port Botany 120305AuditElgasLPGCavern.pdf (191KB)
20023 ELGAS LTD Blacktown 120306AuditElgasBlacktown.pdf (511KB)
2695 HC EXTRACTIONS PTY LTD Kurnell 120303AuditHcExtractions.pdf (140KB)
7494 HUNTSMAN CORPORATION AUSTRALIA PTY LIMITED Matraville 120308AuditHuntsman.pdf (674KB)
11781 INCITEC PIVOT LIMITED Kooragang island 120310AuditIncitecPivot.pdf(142KB)
11793 INCITEC FERTILIZERS LIMITED Moree 120309AuditIncitecFertilisers.pdf (186KB)
5104 LYONDELLBASELL AUSTRALIA PTY LTD Rosehill 120329AuditLyondellbasell.pdf (143KB)
11220 ORICA AUSTRALIA PTY LTD Ravensworth (Lidell) 120304AuditOrica1.pdf (457KB)
2148 ORICA AUSTRALIA PTY LTD Matraville 120325AuditOrica2.pdf (302KB)
245 ORIGIN ENERGY LPG LIMITED Port Botany 120314AuditOrigin.pdf (168KB)
3530 PAX AUSTRALIA PTY LTD Ingleburn 120311AuditPax.pdf (161KB)
2934 POOL RESOURCES PTY LTD Bankstown 120313AuditPool.pdf (357KB)
10000 QENOS PTY LTD Matraville

120316AuditQenosBotany.pdf (22KB)

464 QENOS PTY LTD Port Botany 120312AuditQenosFriendship.pdf (144KB)
13154 RECKITT BENCKISER (AUSTRALIA) PTY LIMITED Erskine Park 120315AuditReckitt.pdf (237KB)
661 SHELL REFINING (AUSTRALIA) PROPRIETARY LIMITED Greenwich 120322AuditShellGoreBay.pdf (451KB)
570 SHELL REFINING (AUSTRALIA) PROPRIETARY LIMITED Camellia (Rosehill) 120317AuditShellClyde.pdf (289KB)
1255 SOLVAY INTEROX PTY LTD Banksmeadow 120318AuditSolvay.pdf (179KB)
n/a – EPA as ARA SYDNEY WATER CORPORATION Warragamba 120321AuditSydWater.pdf (341KB)
6152 TOLL NORTH PTY LTD Arndell Park 120319AuditToll.pdf (148KB)
12485 UNITED INITIATORS PTY LIMITED Banksmeadow 120323AuditUnited.pdf (167KB)
6007 VOPAK TERMINALS SYDNEY PTY LIMITED Port Botany 120320AuditVopak1.pdf (615KB)
6581 VOPAK TERMINALS SYDNEY PTY LIMITED Port Botany 120326AuditVopak2.pdf (614KB)
11308 WOODCHEM AUSTRALIA PTY. LIMITED Oberon 120324AuditWoodchem.pdf (337KB)
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