Clean Hands Dealing with the Environmental framework · Aside from the risk of spill incidents arising from daily operations, old style systems are generally comprised of a single

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Clean Hands – Dealing with the Environmental framework

Hugh Thomson, General Manager - Products

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Enviropacific is an environmental engineering business with more than 200 highly skilled engineers, chemists and scientists operating out of every capital city in Australia and a number of remote locations including Cairns and Townsville.

Full service environmental engineering

Introduction to Enviropacific


Introduction to Enviropacific

Full service environmental engineering

As an environmental engineering business, our product and service offering is focused on:

• Environmental products which provide contamination prevention, response and recovery for many industries;

• Petroleum services offering cradle to grave services for downstream petroleum infrastructure, retail fuel outlets and bulk petroleum handling and storage facilities

• Remediation services that ensure an innovative, cost effective and sustainable solution allowing for contaminated land to be cleaned in a commercially appropriate manner

• Complimentary services including energy services and water management


Presentation Overview

A few topics we will cover today

• Risks The environmental and commercial risks presently facing the marina industry

• Opportunities Growth prospects and commercial opportunities related to environmental management

• Horizon Environmental and legislative direction

• Solutions New technologies, methods and offerings


Industry Overview

Data from 2013 Health of the Australian Marina Industry SurveyAustralian Marinas: Social and Environmental PerformanceRecreational Marine Research Center, Michigan State University


Industry Overview

Data from 2013 Health of the Australian Marina Industry Survey

Australian Marinas: Social and Environmental PerformanceRecreational Marine Research Center, Michigan State University


Risks

Environmental – Fuelling System Risks

Marina owners and operators have traditionally been very risk averse when it came to fuelling systems – and rightly so.

Aside from the risk of spill incidents arising from daily operations, old style systems are generally comprised of a single wall steel tank with single wall steel pipework. They are often exposed in a marine environment, with no containment sumps or other protection.

Compounding this, they were notoriously unreliable.


Risks

Environmental – Containment Risks

Most states have law requiring that any environmentally hazardous liquids, solids and gases must be adequately contained to prevent egress to the environment (including land, waterways, creeks and storm-water).

This is particularly applicable to:

• Hydrocarbons – including petrol, diesel and heavy oil

• Polychlorinated biphenyl (PCBs) – including from coolants

• Volatile Organic Compounds (VOCs) – including from anti-foul and other paint and solvent use

• Other hazardous chemicals and metals – including those used in batteries


Risks

Environmental – Containment Risks

Adequacy of the containment measures is determined by the size and type of the facility, but will almost always include some form of filtration and containment bund.

Australian Standards AS1940 and AS4452 provide guidance.

Environmental and Emergency management plans should anticipate what might happen if a loss of containment was to occur (both on-site and off-site) and how a response might be handled.

Most importantly, these containment measures must be suitably performing, regularly inspected and staff must be trained on how to use them.


Risks

Environmental – Spill Risks

Of course, the most obvious “spill” risk is where there are refueling operations.

Whether you operate a refueling facility or not, you have obligations.

Other spill risks exist, particularly where there is an accident, fire or submersion of a vessel.

You have an obligation to report any spill that might cause “material” harm or severe penalties apply – failure to notify carries penalties of up to $2M (corp) and $500K (ind).


Risks

Commercial – Penalties

If you don’t manage your risk, there is the prospect of onerous penalties:

Fines may apply:

• Tier 1 offences (most serious) – up to $5M (corp) and $1M (ind) and/or 7 years jail

• Tier 2 offences – up to $1M (corp) and $250K (ind)

• Tier 3 offences (least serious) – by penalty notice

Note: penalties may vary from jurisdiction to jurisdiction


Risks

Commercial – Penalties

Economic measures for the industry – Each EPA has regulatory powers to enforce schemes involving economic measures. This generally applies where an industry fails to regulate itself and, when it happens, EPA standards tend to be onerous.

Public shame – Each state EPA has an ability to require offenders to be noted on a public register. This is more than public shaming, it dramatically affects an offender’s ability to successfully bid public work and highlights the possible lack of commitment to sustainability.


Risks

Commercial – Restricting operations

In very serious cases, EPA’s around the country have rights to restrict operations.

The effect of any restriction on operation of a marina could be catastrophic – not just for the owner and operator of the marina, but for any vessel which might be requiring to enter or leave that marina.


Risks

Commercial – Operational

In reality, heavy penalties and shutdowns are not a common occurrence.

That said, there is a very real operational impact to failing to manage risk:

• Standing as a good corporate citizen – most of your customers are lovers of nature and hold the environment in high regard – they want to see you set a high standard.

• Poor environmental risk control significantly increases the chance of other incidents such as fire.

• Ultimately, poor environmental risk control will result in poor sustainability.


Prospects & Opportunities

Converting environmental compliance from a cost line to a revenue line

Businesses that adopt best-practice and work towards sustainability do so on the basis of recognising that environmental best-practice measures are not simply a cost line, but also a revenue opportunity.

Large commercial operators have had this practice for a long time. Most ports and other commercial ventures have environmental levies itemised in their fee structure, or build it into the cost.



Converting environmental compliance from a cost line to a revenue line

The important part to successful implementation is being able to show where the investment has been made and (where relevant) ensuring that the equipment is capable of being easily used by responders – not allowing it to become simply another fee.

Revenue? Really?

The 2004 report “Willingness to pay for “The Environment” in Cross-National Perspective” by DrBruce Tranter (University of Adelaide) found that 53.8% percent of Australians were willing to pay “quite a bit more” or “a little more” to protect the environment.

This number is significantly higher if you are degree qualified, a woman or in a greater than 50% income bracket (2.03x if over $78K).



Refueling isn’t as scary (or as costly) as it may seem

Historically, fuel systems were an expensive cap-ex with an even more expensive maintenance budget – and that is before you start talking about risk.

With a 50/50 split of marinas who do and don’t have refueling capability, that is obviously still a current perception.

Modern systems present a flexible (large or small scale), cost effective, low maintenance, risk-minimised option for marina owners and operators to add additional revenue streams to their businesses.



Marina Utility Vessel

Many marinas own and operate small vessels as part of their operation. These are often single dimension vessels.

Enviropacific is exclusive distributor for MERV vessels, a multi-use modularised vessel with interchangeable modules for a wide range of purposes including utility, emergency response, fire, oil recovery and litter collection.

Many of our clients recognise that, with such a flexible vessel, opportunities exist to offer services to local authorities and service providers resulting in increased utilisation and again, converting what was traditional a cost line to a revenue line.


The Horizon

Zero Harm

Many regulators in Australia have made it clear that a zero harm standard is the standard they want to strive for.

This means that what might have once been acceptable, may not be acceptable going forward.

It also means that there is an increasing intolerance for offenders, whether first time or repeat offenders and a general expectation that Australian businesses operate in a best-practice, sustainability-focused mindset.

Practically, what does that mean?


The Horizon

Higher Discharge Standards

Many marinas use separators or interceptors as a means of controlling contaminant discharge.

As a result of increasing standards, many of these systems have effectively been made non-compliant and require replacement with modern systems or retro-fit of appropriate filters to reduce the parts-per-million discharge.

While some regulators have been gracious in enforcement, this is starting to gain momentum. With all the large industrial users (such as power generators) having upgraded, regulators are setting their sights on smaller operators.


The Horizon

Expectations of fuel facilities

As mentioned previously, now defunct standards relating to fuel systems allowed for:

• Single wall steel tanks

• Single wall steel pipes

• No containment sumps or other modern containment measures

Further, these old systems were notoriously unreliable and, if not adequately serviced, presented substantial risks.


The Horizon


New standards present a very different offering:

• Double wall fiberglass USTs (underground storage tank);

• Dual contained above ground tanks;

• Double wall HDPE (high-density polyethylene) piping.

Vapour recovery systems are generally required on fuel systems in NSW. Exemptions exist in certain jurisdictions for small operators, but best practice would suggest this should be included.


The Horizon


Importantly, new systems :

• perform far better in marine environments than older steel based systems which corroded rapidly;

• require significantly less maintenance;

• offer far greater reliability;

• present a risk-minimizing, revenue generating solution.


The Horizon

Spill Kits

Spill kits should NOT be purchased “off the shelf”.

Your obligations are to ensure that you have considered your risk and have equipment capable of dealing with it should that risk arise and regulators are not accepting generic response kits.

Marinas are not all the same – finger configuration, harbor layout, average vessel length, refueling facilities and any number of other considerations should be had when determining what an appropriate spill kit might be.


The Horizon

Responsibility for others

Traditionally, corporations and individuals had a responsibility to take care of their actions.

In our sector, we see an increasing trend requiring corporations and businesses to consider not only their own possible risk scenarios and how they might be managed, but also those with whom they interact. This is already the case for material goods handling (such as fuel) and transport (chain of responsibility) and appears to be increasing.

If you haven’t already, Marina owners and operators should begin to prepare themselves and consider how they intend to respond to non-organic incidents – accidents, spills and discharges.


Solutions

Fuel handling and technology

We are a national petroleum services contractor to Shell, BP, Caltex, 7-Eleven and a number of others. As a result of these relationships, we have significant exposure to industry leading, best practice and cost effective solutions.


Solutions

Fuel handling and technology

We have a range of technically robust, innovative and cost-effective solutions including:

• Containment dispenser sumps

• Shoreline Valves

• Automatic Tank Gauging

• Electronic Leak Detection


Solutions

Spill Response

On-water spill response is highly manageable with the right equipment.

Critical to any successful spill response are two key factors – speed and effectiveness.

Highly cost-effective first-response solutions exist for marinas.

For example, the BoomBag is a 250m+ boom capable of being deployed in 45seconds and being towed at 15 knots (prior to deployment) – it can also function as a rescue floatation device


Solutions

Spill Response

Near marina spill booms and solutions are something all Marina owners and operators should be familiar with in functionality.

Technical advances have resulted in far greater effectiveness.

Our range of marina and harbor spill equipment includes proprietary polymer based products that effectively absorb and, unlike traditional absorbents, encapsulate and solidify hydrocarbons.

This polymer comes in a number of formats including booms, fabric and powder.


Solutions

Spill Response – more than just a bit of kit

Managing risk requires a whole of system approach.

Action was taken recently against a marina in NSW for a diesel spill and it resulted not just in the financial penalty but also strong criticism that:

• Response equipment was not suitable or adequate; and

• Responders had not been trained in how to use the equipment.

This is a common occurrence.

Records should be maintained relating to risk assessments, equipment inspections and staff training.


Solutions

Containment

Our engineered range of products include filtration and containment solutions employing the our proprietary polymer, which allows for the securing and solidification of hydrocarbons, on a gravity fed basis, to non-detect levels (if required).

We also have a range of land based spill response equipment.


Solutions

Containment

Our bund solutions are some of the most innovative, high performing, cost effective solutions in the market.

Used by a range of businesses from large public utility companies to small businesses, our solutions are well engineered for each of our customers.

Most importantly, our engineers are some of the most regarded in Australia and capable of designing low cost and high performing solutions regardless of your requirements.


Solutions

Helping your customers

We have a range of products for boat owners, perhaps none more cost-effective and highly useful than the Bilge Bag and Bilge Sock.

Despite its small size, low cost and understated appearance, these two bilge applications encapsulate residue fuel, absorb potentially hazardous and flammable vapours and can be disposed of in general waste.

Our recommendation is that each marina has a range of suitable products available for its customers. Ultimately this will help owners and operators from having to identify customers discharging sheen through their bilges.

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Disclaimer

This presentation is for general information only.

The information provided is not legal or compliance advice.

Details relating to any products mentioned are marketing material only. Please see relevant technical data sheets for specific performance metrics.

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Thank you

If any of the topics covered today are of interest to you, please come and talk with us in the exhibition hall.

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Hugh Thomson

General Manager – Products+61 457 904 [email protected]

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Clean Hands Dealing with the Environmental framework · Aside from the risk of spill incidents arising from daily operations, old style systems are generally comprised of a single