Appendix D CIF Report PDF

Non-Recyclable Plastic to Liquid Fuel
Processing Facility
Failure Modes Effects Analysis (FMEA) for Critical
Infrastructure
For FOY Group Limited
8 March 2017
Doc. No.: J-000241-REP-FMEA

Revision: A
Sydney Melbourne
Arriscar Pty Limited Level 26 Level 2 Riverside Quay
ACN 162 867 763 44 Market Street 1 Southbank Boulevard
www.arriscar.com.au Sydney NSW 2000 Southbank VIC 3006
T: +61 2 9089 8804 T: +61 3 9982 4535
Plastics to Liquid Fuel: Critical Infrastructure FMEA
Distribution List
From To
Name Organisation
(Issue) (Issue)
John Sneddon FOY Group Limited - A
Project Master File Arriscar Pty Limited Draft A
Document History and Authorisation

Rev Date By Description Check Approved
A 8 Mar 2017 JPM Consultation draft PS -
Arriscar Pty Limited, and its respective officers, employees or agents are individually and collectively referred to in this
clause as 'Arriscar'. Arriscar assumes no responsibility, and shall not be liable to any person, for any loss, damage or
expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has
signed a contract with Arriscar for the provision of this information or advice and in that case any responsibility or liability
is exclusively on the terms and conditions set out in that contract.
© Arriscar Pty Ltd.
Contents
Distribution List ........................................................................................................................................ 2
Document History and Authorisation........................................................................................................ 2
Notation .................................................................................................................................................. 5
1 Introduction ................................................................................................................................... 6
1.1 Background .................................................................................................................................... 6
1.2 Objectives ...................................................................................................................................... 6
1.3 Scope ............................................................................................................................................. 6
1.3.1 Scope of Analysis ........................................................................................................................... 6
1.3.2 Scope of Facilities and Operations ................................................................................................ 7
2 Methodology .................................................................................................................................. 8
2.1 FMEA Methodology ....................................................................................................................... 8
2.2 Generic Failure Modes ................................................................................................................ 10
3 Facility Description ....................................................................................................................... 12
3.1 Site Location ................................................................................................................................ 12
3.2 Facility Overview ......................................................................................................................... 12
3.3 Plastic Storage Area and Extruder ............................................................................................... 15
3.4 Processing Area ........................................................................................................................... 15
3.5 Tank Farm .................................................................................................................................... 17
3.6 Tanker Loading Area .................................................................................................................... 18
3.7 Staffing......................................................................................................................................... 18
3.8 Security ........................................................................................................................................ 18
3.9 Proposed Prevention and Mitigation Control Measures ............................................................. 19
3.9.1 Spill Prevention and Mitigation ................................................................................................... 19
3.9.2 Stormwater system ..................................................................................................................... 19
3.9.3 Fire Prevention, Detection and Mitigation .................................................................................. 20
3.9.4 Safety Management System ........................................................................................................ 20
4 Systems and Equipment for FMEA................................................................................................. 21

5 Assessment of Critical Infrastructure ............................................................................................. 22
5.1 Control of Fugitive Emissions ...................................................................................................... 22
5.2 Control of Tail Gas Emissions....................................................................................................... 23
5.2.1 Excess Tail Gas ............................................................................................................................. 23
5.2.2 Cyclone Burner Failure ................................................................................................................ 23
5.2.3 Emergency Flare Failure .............................................................................................................. 24
5.3 Containment of Contaminated Stormwater................................................................................ 24
5.3.1 Spill Containment Failure ............................................................................................................ 25
5.3.2 First Flush System Failure ............................................................................................................ 26
5.4 Critical Infrastructure for Prevention of Vessel Rupture ............................................................. 26
5.5 Critical Infrastructure for Control of Fires and Explosions .......................................................... 27
6 Findings and Recommendations .................................................................................................... 29

6.1 Findings........................................................................................................................................ 29
6.2 Recommendations....................................................................................................................... 29
7 References .................................................................................................................................... 30
Appendix A FMEA Worksheets...................................................................................................... 32
Doc Number: J-000241-REP-FMEA

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Appendix B Hazard Identification.................................................................................................. 48
List of Figures
Figure 1 Overview of FMEA Process ........................................................................................................... 9
Figure 2 Location of Proposed Facility ..................................................................................................... 12
Figure 3 Site Layout .................................................................................................................................. 14
Figure 4 Process Flow Diagram ................................................................................................................ 17
List of Tables
Table 1: Systems and Equipment for Control of Emissions and Stormwater .................................................. 21

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Notation
Abbreviation Description
ACT Australian Capital Territory
Arriscar Arriscar Pty Limited
DG Dangerous Good
DP&E NSW Department of Planning and Environment
EPA ACT Environment Protection Authority
FMEA Failure Modes and Effects Analysis
FMECA Failure Modes and Effects Criticality Analysis
FOY FOY Group Limited
FSS Fire Safety Study
HAZID Hazard Identification
HAZOP Hazard and Operability
HIPAP Hazardous Industry Planning Advisory Paper
HIWD Hazard Identification Word Diagram
LPG Liquefied Petroleum Gas
NSW New South Wales
PHA Preliminary Hazard Analysis
PPE Personal Protective Equipment
QRA Quantitative Risk Assessment
SIL Safety Integrity Level
SMS Safety Management System
t tonne
tpa tonnes per annum
tpd tonnes per day

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1 INTRODUCTION
Arriscar Pty Limited was engaged by FOY Group Limited (FOY) as an independent consultant to
undertake an assessment of critical infrastructure failure for their plastics to liquid fuel facility in the
Australian Capital Territory (ACT).
The intention of the study was to evaluate related systems with regard to potential failure modes
and their effects on safety, operability of the equipment, and the environment. Hence, the main
objective was to identify and describe any aspects of the design that need to be clarified and / or
resolved or need extra focus during operation.
1.1 Background
FOY proposes to construct a 200 tonne/day waste plastic to fuel facility. Construction and operation
of the facility will occur in 4 stages:
Stage 1
• Construction of site infra-structure and services (power, water, etc.).
• Construction of office, feedstock storage, tank farm and processing buildings.
• Installation of the first 50 tonne/day processing module.
Stage 2
• Installation of the 2nd 50 tonne/day module.
Stage 3
• Installation of the 3rd 50 tonne/day module.
• Expansion of the tank farm.
Stage 4
• Installation of the 4th 50 tonne/day module.
• Expansion of the workshop facility to accommodate module construction for overseas
parties.
1.2 Objectives
The principal objective of the study was to perform an independent assessment of critical
infrastructure failure for the FOY Plastics to liquid fuel facility. For this assessment, critical
infrastructure is considered to include equipment provided for control of emissions and control
measures for protection against abnormal events that may involve a loss of containment, fire or
explosion.
1.3 Scope
1.3.1 Scope of Analysis

The ACT Environment Protection Authority (EPA) has stipulated to FOY that the following items
should be addressed:
- Control of fugitive emissions from process equipment and storage vessels;
- Control of tail gas emissions from the process;
- Prevention of the rupture or loss of containment of hydrocarbon gas or liquid vessels

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- Prevention or control of fire or explosion in the facility; and

- Prevention of contaminated stormwater exiting the facility.
1.3.2 Scope of Facilities and Operations

The following facilities and operations involving hazardous materials (e.g. Petrol) were included in
the scope of the study:
• Plastic storage area and screw press densifier.
• Processing area.
• Tank farm with vertical storage tanks for diesel, petrol and rework product.
• Road tanker loading area.
• Fire protection system.
• First flush system for storm water and other run-off (Designed to contain the first 15 mm
of any rain event with c. 150 m3 total storage).
The offices and amenities, workshop and vehicle parking area were excluded from the scope of the
study.
The FMEA is limited to the operational phase of the facility.

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2 METHODOLOGY
The following approaches where adopted for this study:
- Undertake a Failure Modes and Effects Analysis (FMEA) for plant and equipment at the
facility for which a failure would lead to an undesired outcome, such as an emission of
hydrocarbon gas or liquid to the air or stormwater (Also refer to Section1.3.1).
- Undertake a review of the Preliminary Hazard Analysis (PHA) [Ref 1] to identify and assess
the hazardous effects of a hydrocarbon release from vessels and plant, and to review the
prevention, detection and mitigation control measures in the design.
2.1 FMEA Methodology

FMEA is a qualitative analysis technique that involves identifying each failure mode for each
equipment system, sub-system or component and the corresponding effects of these potential
failures. The method is based on IEC Standard 60812, International Electro Technical Commission,
“Analysis techniques for system reliability – Procedure for failure mode and effects analysis (FMEA)”.
FMEA provides the following:
• Failure modes for the components (both single mode and common mode failures). Common
mode failure is a result of an event which causes a coincidence of failure states in two or
more components.
• The local and global consequences of the failure event.
• Identification of how the failure modes are, or can be, detected, and devise or describe
existing provisions and safeguards that prevent the system from failing.
• Identification of measures to reduce the risk of failures for equipment.
• The analysis provides a way to alert designers if hazards are present when the system fails.
This will also highlight areas that need extra focus during operation and that may be
beneficial to implement in order to increase safety and reduce the probability or
consequence, and thus the risk, of the relevant failure mode.
The systems were be broken down into subsystems and/or functions the equipment or system
should fulfil in order to work as intended.
The figure below shows the methodology for the FMEA (Ref: IEC 60812-2006). The detailed FMECA
approach was not undertaken at this stage of the project.

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Figure 1 Overview of FMEA Process
The FMEA technique is used for qualitative and semi-quantitative analysis of engineering systems.
It often provides the starting point for reliability analyses, and enables the analyst to gain an insight
into possible critical failures of the system being analysed. Furthermore, the obtained information

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may be used as a benchmark input to further develop the system and to enhance its overall
reliability.
The main goals of the FMEA are:
1. Identify failure modes for the component and the resulting effects on each subsystem at a
local level and the total system as a whole. Particular attention is paid to common mode
failures that can eliminate the system redundancy due to failed items or components.
2. Identify how the failure modes are or can be detected, and devise provisions and safeguards
that prevent the system from failing. If none is feasible or attainable, the analysis provides
a way to alert designers if hazards are present when the system fails.
The FMEA was undertaken as a desktop exercise reviewing project documentation, primarily the
Critical Infrastructure Failure Report [Ref 6] and the EIS [Ref 7], in consultation with FOY engineers
as required. THE FMEA worksheets are given in Appendix A.
2.2 Generic Failure Modes

Typical common mode failures include:
• Design, software, rating
• Manufacturing, batch related component flaws
• Environment: electrical interference, temperature cycling, vibration
• Human factors: incorrect operating or maintenance actions / procedures
Typical single mode failures include:
• Structural failure (rupture)
• Physical binding or jamming
• Vibration
• Fails to remain (in position)
• Fails to open
• Fails to close
• Fails open
• Fails closed
• Internal Leakage
• External Leakage
• Fails out of tolerance (high / low)
• Erroneous operation
• Restricted flow
• False actuation
• Fails to stop
• Fails to start
• Premature Operation
• Delayed Operation
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• Erroneous input (increased / decreased)

• Erroneous output (increased / decreased)
• Loss of input
• Loss of output
• Shorted (electrical)
• Open (electrical)
• Leakage (electrical)

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3 FACILITY DESCRIPTION
3.1 Site Location
The proposed development site is at 36 Couranga Crescent (Block 11, Section 21) (Refer to Figure
2), approximately 11 km South of Canberra’s central business district and approximately 4 km West
of Lake Jerrabombera and the Lake Jerrabombera township.
Figure 2 Location of Proposed Facility
3.2 Facility Overview

The proposed facilities and operations are relatively straightforward. Non-recyclable plastic (waste
polystyrene, polyethylene and polypropylene) will be delivered to the site by truck. This will be
unloaded from the truck and stored in a warehouse before being transferred to the processing area.
The hydrocarbons produced in the processing area (Petrol, diesel, etc.) will be stored in a tank farm
before being loaded into road tankers and delivered to customers.
~ 780 m
The processing plant will operate 24 hours a day, 7 days a week. Truck and tanker movements will
occur between the hours of 6.00 a.m. and 10.00 p.m. Monday to Friday and 8.00 a.m. to 4:30 p.m.
on Saturdays and Sundays.
The main storage and processing facilities are described in more detail in Sections 3.3 - 3.6. Other
on-site facilities will include:

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• An office, including amenities, will be in the Eastern part of the site (excluding the
driveway area). A car park will be located adjacent to the office area.
• A hardstand area containing the first flush system will be in the northeast corner of the
site. The first flush system has been designed to contain the first 15mm of rain of all hard
stand areas excluding areas covered by impervious roofing.
• The fire protection system will be in the south-east corner of the site. The fire protection
system has been designed to provide a deluge of 20 minutes for the main processing
area.
• A workshop facility for general site equipment maintenance and spares storage
requirements will be in the northeast of the main processing area.
The proposed site will be accessed using Couranga Crescent, as shown on the site plan (Refer to
Figure 3).
The site surface will consist of sealed concrete in the vehicle and processing areas, gravel in areas
between processing and vehicle access, and an area to the west of the site which will be reserved
as a grassed area.

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Figure 3 Site Layout

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3.3 Plastic Storage Area and Extruder

The plastic storage and densification areas will be located to the north of the processing shed on
the northern boundary.
These areas will be covered, bunded and protected by the site fire protection system.
3.4 Processing Area

The processing area, which houses most of the processing equipment will be in the centre of the
site. The main products will be diesel and petrol, with some liquefied petroleum range gas (LPG) to
be captured and consumed for heating during the process. The plastic will yield (by mass)
approximately 65% diesel, 20% petrol and 15% LPG.
The shed and processing units, which are open on four sides, will be protected by a fire protection
system. All processing areas will be on sealed concrete flooring with bunds to capture spills.
The waste non-recyclable plastic to fuel (pyrolysis) process is described below and shown in the
process flow diagram provided in Figure 4.
1. Feedstock delivery system. The densified plastic tablets will pass into an low oxygen gas purged
hopper and then through a double vapour lock consisting of a double slide gate and plug screw
arrangement to remove all air associated with the feed stock. This will ensure both a continuous
supply of feedstock to the processing plant and ensure air does not enter the catalytic reactor
(rotary kiln) with the plastic, as this could cause oxidation of the hydrocarbons.
2. Catalytic reactor. In the catalytic reactor, the feedstock and small quantities of activated
bauxite contacts the product oil/catalyst slurry and are rapidly heated to over 400 degrees
Celsius (oC). Activated bauxite was chosen as a catalyst due to its ability to assist in the
production of liquid hydrocarbons (diesel and petrol) and absorb impurities. The activated
bauxite will be stored in 20 kg bags in the workshop area. At any time, there will be less than 1
tonne stored on site (i.e., approximately one week’s supply). The process will consume 20 kg
of activated bauxite every 3 hours. The catalytic reactor consists of the following components:
• A large horizontal cylinder enclosing a smaller cylindrical vessel, the rotary kiln or
catalytic reactor. Hot gases produced by the cyclone combustor pass through the
interstitial space between the two vessels heating the feedstock, catalyst and hot oil.
• The depolymerisation reaction occurs in the catalytic reactor. The reactor houses a
rotary stirrer and is sealed at both ends. The melting plastic depolymerises into
hydrocarbon gases ranging from LPG to heavy wax. The majority of the gases
produced are in the liquid fuel range (petrol and diesel).
• Hot vapour ducts remove the gaseous hydrocarbons produced in the
depolymerisation reaction to the scrubber.
• The residual non-converted material comprising spent catalyst and char (carbon
black) are drawn off the catalytic reactor for disposal.
3. Packed column scrubber. Hot vapours from the catalytic reactor pass through a packed column
scrubber where they are cooled and washed free of particulates by the reflux diesel stream.
Solid particles, dust (including any residual metal dust) and heavier oils and waxes are removed
by the reflux diesel stream and fall back into the catalytic reactor to undergo further
depolymerisation.
4. Fractionation column. The vapours from the packed column scrubber pass then pass into a
conventional hydrocarbon fractionation column where diesel and petrol / LPG range
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hydrocarbons are separated. Reflux diesel (diesel that has been previously fractioned) is
pumped from the small tank at the bottom of the fractionation column to the packed column
scrubber through a flow control system.
5. Impurity Extraction System. The diesel phase passes to the impurity extraction system where
it is contacted in a counter flow liquid/liquid extraction column. This system removes such
impurities as Polyaromatic hydrocarbons, Sulphur compounds, colour compounds and
oxygenates.
6. Vacuum drying column. The diesel fraction that has had impurities removed may still contain
trace water. Water is removed by passing the diesel fraction through the vacuum drying tower.
The diesel fraction falls through tower packing while exposed to a high vacuum at a
temperature of approximately 110 degrees C, causing the water to boil off and be directed to
the primary condenser. The produced diesel is piped to the above ground diesel storage tanks.
7. Primary condenser. The lighter-end vapours flow from the fractionation tower to the primary
condenser, where petrol and water are condensed from the vapour stream. The petrol is a
finished product and is piped to the aboveground petrol storage tanks. Reflux petrol from the
storage tanks is pumped through a flow control mechanism to the top of the fractionation
column tower to assist in the fractionation process. The water fraction is directed to the
reboiler where it is reheated to remove trace petrol. Post this step it is pumped to the
wastewater treatment facility where it is treated before reuse as process water in the cooling
tower. In the unlikely event that there is an excess of water, FOY will discharge the excess water
to the sewer in accordance with the requirements of the trade waste permit.
8. Chilled vent condenser and compressor. Gas vapours (primarily LPG), which do not condense
in the primary condenser are ducted to the chilled vent condenser which is chilled utilising an
industry-standard cold glycol water system. Petrol is condensed from the vapours and piped to
the petrol storage tank. Non-condensable gases from the chilled vent condenser are
compressed and piped to the aboveground LPG storage vessel. Gases that do not condense in
the compression process are drawn off and piped to the cyclone combustor for use as fuel.
9. Cyclone combustor. The cyclone combustor produces the hot gases and heat required for the
depolymerisation process. The combustor uses LPG for start-up after which a mixture of LPG
and non-condensable gases provides fuel for the burner. Hot combustion gases flowing from
the cyclone combustor at over 1,100 oC for over 2 seconds are mixed with recycled flue gas and
enter the interstitial spaces between the catalytic reactor and outer cylinder at 900oC.
10. Heat recovery unit. Flue gases flowing from the interstitial spaces between the outer cylinder
and catalytic reactor pass through a heat recovery unit where heat energy is recovered to
reduce the plants fuel consumption lowering emissions to atmosphere. A small amount of the
flue gases are vented to atmosphere via a stack with a real-time monitoring module for air
pollutants.
11. Pyrolysis residue recovery system. Residual non-converted material (pyrolysis residue) exits
the catalytic reactor via vapour locks to a sealed metal cooling vessel where it cools naturally.
During cooling the vessel is subjected to a slight negative pressure by the fugitive vapour
collection system to ensure any remaining vapours are captured and thermally oxidised in the
cyclone combustor. The content of the non-converted material comprises filler materials (from
the plastic feedstock), char and admix.

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Figure 4 Process Flow Diagram
Vacuum dryer
Diesel
3.5 Tank Farm

The tank farm will be located to the south-west of the main processing area, 10 m inside the
southern boundary. The Stage 4 facility will include:
• 3 x 290 kl vertical diesel tanks
• 2 x 290 kl vertical petrol tanks
• 1 x 80 kl vertical rework tank
• 1 x 150 kl vertical diesel day tank
• 1 x 80 kl vertical marine diesel day tank
• 1 x 80 kl vertical Petrol day tank
• 1 x 27 kl horizontal LPG tank
These tanks will be in a sealed concrete bund.

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The dimensions of tank farm bund are: 33.0 m x 10.0 m x 1.2 m. This equates to total retention
capacity of approximately 396 kilolitres. The Australian Standard AS1940–2004: The Storage and
Handling of Flammable and Combustible Liquids requires a bund capable of retaining at least 110%
of the volume of the largest container. The proposed bund can contain approximately 136% of the
largest tank (one of the 290 kilolitre diesel tanks) inside the bunded area and therefore complies
with AS1940-2004 and may contain some firefighting water / foam in the event of a fire.
3.6 Tanker Loading Area

A tanker loading area will be located on a hardstand surface directly east of the tank farm.
The road tankers can carry 28 tonnes of end-product for a single truck and 42.5 tonnes for a B-
double. Assuming the use of B-double tankers, this will equate to five road tankers (diesel or petrol)
being loaded per day for the Stage 4 development.
3.7 Staffing
The workforce at full plant capacity will include:
• One facility manager;
• Fourteen facility operators;
• One logistics manager;
• One plant engineer;
• Three logistics operators;
• One fitter;
• One engineer;
• Three maintenance staff;
• One lab supervisor;
• One lab technician;
• One admin assistant; and
• One accounts clerk.
3.8 Security
The site security system will include:
• Physical Barriers – The site will be fenced with a 1.8 m high chain mesh (cyclone) security
fence with triple barbed wire along the top;
• Signage;
• Shift security checks;
• Emergency action plans; and
• Background checks on employees prior to employment.

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3.9 Proposed Prevention and Mitigation Control Measures
3.9.1 Spill Prevention and Mitigation

Mitigation of the impacts of the spills and leakages will be managed through implementation of the
following measures:
• All liquid storage and handling floor areas will be constructed from sealed concrete
surfaces;
• Supply and maintenance of suitable spill response kits at the site;
• Regular inspection of bund integrity. Where integrity issues are observed, bunds will be
repaired;
• Regular inspection and maintenance of the overfill protection valves;
• Review and revision (if necessary) of FOY’s existing emergency spill response procedures
(to be incorporated into the EMP);
• Training of all operators and truck drivers in appropriate spill response techniques and
provision of regular refresher training;
• Conducting tanker fuel load-out activities on the designated hardstand areas only and
maintaining the spill catch pit; and
• Regular inspection and maintenance of the first flush storm water system.
3.9.2 Stormwater system

Stormwater runoff generated in contaminated portions of the site such as the main process
areas will be contained onsite in bunded areas and processed through the waste water
treatment plant.
Stormwater runoff generated from roadways collects in the north-eastern corner of the site
and is processed through the first flush system. Key features of the system are summarised
below:
• The system will consist of two compartments. A sedimentation / oil collection
compartment which top flows into the secondary first flush compartment. Once this
compartment is full, the inlet automatically closes and diverts remaining water to storm
water.
• The water then flows into the below-ground sedimentation tank where additional
sediments are removed before the water reaches the first flush tank.
• The first sedimentation / oil separation compartment has an effective capacity of 3 kl
and second first flush compartment has an effective capacity of 150 kl. The tanks are
emptied immediately following rainfall events. The water is pumped from the below-
ground first flush tank to the aboveground tanks which have an effective capacity of 120
kl by a float-operated submersible pump.
• First flush stormwater collected in the below-ground tanks is either removed offsite by
a licensed waste contractor or pumped through a sand filter via the above-ground tanks
to the wastewater treatment facility for treatment and use as process water after each
rainfall event.
• Excess clean stormwater not captured during the first flush event (including stormwater
runoff from roofed areas of the site) is diverted to the municipal stormwater system.

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3.9.3 Fire Prevention, Detection and Mitigation

Mitigation measure to prevent fires or explosions in the facility include:
Prevention and Detection
• Intrinsic design of the main processing facility to prevent fuel sources contacting air.
• Plant operating policies and procedures.
• Adherence to electrical hazardous area zoning requirements.
• Weekly housekeeping reports (including checks of the deluge systems).
• No Smoking policy on site.
• Hot work permitting system.
• Perimeter sprinklers to prevent fires from outside entering the facility.
Fire Mitigation
• Fire hydrant system.
• Fire extinguishers located strategically throughout processing and feed preparation and
storage areas.
• Fully automatic plant deluge system including:
• Fire water storage tank (290,000 litres).
• Foam suppression system.
• Automated diesel fire pump (Capable of delivering 160 l/s at 800 kPa).
• Back to base notification to local fire station.
• Staff and contractor fire-fighting training.
• Regular refreshers with local Fyshwick fire station.
3.9.4 Safety Management System

A Safety Management System will be developed for the operations at the proposed facility.

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4 SYSTEMS AND EQUIPMENT FOR FMEA

The FOY plastics to liquid facility was broken down into systems and equipment for the FMEA, as
shown in Table 1. The systems identified are based on the infrastructure provided in the design to:
• control fugitive emissions from process equipment and storage vessels;
• control tail gas emissions from process; and
• prevent contaminated stormwater exiting the facility.
Systems and equipment that are not related to the above points are excluded from the scope of the
FMEA.
Table 1: Systems and Equipment for Control of Emissions and Stormwater
# System Equipment
1 Catalytic Reactor Slide Gate
Plug Screw
Packed gland seals
2 Fugitive Emission Control Collection Fan
System
System Ducting
Cyclone Burner
3 Catalytic Reactor Pressure Pressure Transmitter
Control System
Pressure Controller
Gas Compressor (including VSD)
4 Hydrocarbon Condensing Cooling Water Pump
System
Cooling Tower
Chilled Vent Condenser
5 Gas Destruction System Cyclone Combustor
Module Diverter Valve
Flare Diverter Valve
6 Emergency Flare System Flare Pilot
7 Spill Containment Spill Containment Bunds
8 First Flush System First Flush Hydrocarbon Recovery Tank
First Flush Diverter
Surface Drains

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5 ASSESSMENT OF CRITICAL INFRASTRUCTURE

An analysis was undertaken for systems and equipment identified as being critical in maintaining
control over the following:
• fugitive emissions from process equipment and storage vessels;
• tail gas emissions from process;
• contaminated stormwater;
• gas or liquid vessels rupture; and
• fire or/and explosion prevention mitigation.
5.1 Control of Fugitive Emissions

The process used in the plastics to liquid fuel facility requires a constant feed of solid raw material
to be feed to the catalytic reactor where depolymerisation takes place. In addition, solid waste in
the form of ash is created as a by-product which must also be continuously removed. The conditions
within the catalytic reactor are such that hot hydrocarbon gases are formed. As such, there is the
potential for fugitive emissions from the solid material feed and discharge points.
Fugitive emissions from the catalytic reactor system are controlled via the following three layers,
two to prevent the emission, and one mitigative layer to collect the emission prior to dispersing to
the atmosphere should the two prevention layers fail.
The prevention layers are:
• Sealing devises at the solid feed and discharge points; and,
• System pressure control to maintain a slightly negative pressure.
The mitigative layer is provided by fume hoods at each potential release point which collect any
potential emission and direct it through to the air intake of the module cyclone burner where it is
consumed back within the process.
A fugitive emission from the catalytic reactor system would only result in the event of a failure of all
three layers of protection. The FMEA, as detailed in Appendix A, identified the following common
cause failures which have the potential to affect all three layers:
• PLC failure
• Total loss of power
For both common cause failure modes, the protective layers will respond by going to their fail-safe
position/state as follows:
• A PLC failure will shutdown the module closing the slide gates and venting the gas within
the system to the emergency flare.
• A total loss of power would result in the slide gate hydraulic rams closing and an
immediate shutdown of the process with venting of gas within the system to the
emergency flare.
It is recommended that a Safety Integrity Level (SIL) assessment be undertaken to assess the
reliability of these protective functions.

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5.2 Control of Tail Gas Emissions

The light end gases, or ‘tail gas’, generated in the process are stored and/or consumed within the
process as a fuel source for both the catalytic reactor cyclone burners and the site boiler. Tail gas
may be emitted to the atmosphere via the cyclone burners (normal condition) or the emergency
flare (abnormal condition).
The following may lead to higher than expected emissions to the atmosphere:
• Excess tail gas in the system;
• Cyclone burner failure; or
• Emergency flare failure.
5.2.1 Excess Tail Gas

The amount of tail gas generated is managed by condensing as much of the lighter end hydrocarbons
generated within the process into the product streams. A failure of the condensing system will
rapidly increase the quantity of tail gas generated with heavier hydrocarbons being carried over to
the LPG system, including storage. As the LPG in the system is not dispatched from the site, but
consumed by site utilities, if the generation rate exceeds the consumption rate for too long a period
then there is the potential for the need to divert the tail gas to the Emergency Flare. While the
hydrocarbon gases will combust in the Emergency Flare, the residence time is lower than that of a
thermal oxidiser, such as the cyclone combustor, and complete destruction of harmful materials
may not occur leading to a discharge to atmosphere.
From the FMEA, as detailed in Appendix A, is was found that a failure in the supply of cooling water
to the primary condenser would result in a sudden increase in tail gas generation. The design
includes a diesel back up cooling water pump, which is programed to start on low cooling water
supply pressure. Furthermore, availability of the diesel backup cooling water pump has been
interlocked as a permissive within the PLC logic to ensure that the plant cannot run if the backup
diesel cooling water pump is not available.
A failure within the cooling tower, either through fouling or a fan failure, will result in a gradual
increase in tail gas generation as the temperature of the cooling water supply to the Primary
Condenser gradually increases. The cooling tower condition monitoring and water quality tests are
to be managed by operations.
A failure in the chiller vent condenser system will result in a very slight increase in tail gas as the
chiller vent condenser is downstream of the Primary Condenser where the bulk of the heavier
hydrocarbons are condensed out. Failures of the chilled vent condenser were found to
contribute more to potentially off spec product rather than an emission.
5.2.2 Cyclone Burner Failure

While the cyclone burners function is to provide heat for the catalytic reactor it also provides an
emission control function in its capacity as a thermal oxidation unit of the tail gas generated in the
process. A failure of the cyclone burner may result in an increase of emissions beyond the licenced
allowable limits. In the event of a revealed failure within the cyclone burner system a shutdown will
be initiated and the tail gas will be automatically diverted to the Emergency Flare where the
hydrocarbon gases will be combusted.
While the Emergency Flare will combust the hydrocarbon gases, the residence time is lower than
that of a thermal oxidiser, such as the cyclone combustor, and complete destruction of harmful
materials may not occur leading to a discharge to atmosphere. However, as the cyclone combustor

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is also the heat source for the catalytic reactor, tail gas formation will be rapidly reduced on a
module shutdown.
The following failure modes were identified for the cyclone burner:
• Burner Flame Out – Full failure of a single cyclone combustor;
• Loss of control of fuel to air mixture ratio - Partial failure of a single cyclone combustor;
and
• Loss of power - Full failure of all cyclone combustor.
The design provides for automatic detection of the above failure cases with associated actions
undertaken by the PLC to control or shutdown as required.
A full failure of a single cyclone combustor will result in an immediate shutdown of the module with
the diversion of the gas to the remaining operating cyclone combustors. A partial failure of a single
cyclone combustor will first attempt to bring the fuel air ratio back within the operating limit. If the
fuel to air ratio is not brought back within the operating limits within 1 minute of the excursion a
shutdown of the module will be initiated with the diversion of the gas to the remaining operating
cyclone combustors.
In the event of a total power loss the plant is shutdown and flow of gas to all cyclone burners is
diverted to the Emergency Flare.
The diverter valves were also reviewed in the FMEA, as detailed in Appendix A, as a failure of the
diverter valve to actuate and divert the flow away from a cyclone combustor on demand will result
in a release of un-combusted gas via the module stack to the atmosphere.
It is recommended that a SIL assessment be undertaken to assess the reliability of the cyclone
combustor burner management system interfaces with the plant PLC and the diverter valve
functionality to ensure the risk is adequately reduced.
5.2.3 Emergency Flare Failure

The function of the Emergency Flare is to safety dispose of excess hydrocarbon gas within the
process in the event of a plant upset or emergency condition. A failure to ignite the hydrocarbon
gas being diverted to the flare will result in the formation of a flammable vapour cloud.
The primary failure mode identified in the FMEA, as detailed in Appendix A, was a loss of the pilot
light on the flare tip either through a loss of pilot gas supply or a failure to ignite the pilot. The flare
pilot flame is monitored by the PLC and a ‘planned’ module shutdown will be initiated on loss of
pilot light. A ‘planned’ module shutdown is not a plant upset or emergency condition and flow will
not be sent to the flare during this category of shutdown.
The exact pilot gas supply configuration was not confirmed at this stage of the project, however, it
is recommended that the pilot gas supply be suitably independent of the process to ensure a loss of
pilot gas will not result from any plant upset or emergency condition. This may include an LPG
cylinder backup supply on loss of pilot gas.
5.3 Containment of Contaminated Stormwater

A release of raw material (plastic) or hydrocarbon liquid may result in an offsite excursion with the
potential to contaminate the municipal stormwater system. The potential causes for loss of
containment of raw material or hydrocarbon liquid are detailed in Section 5.4.

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All ground surfaces at the facility where hydrocarbons are handled and stored are designed to
ensure that any potential spillage of liquid hydrocarbon will not leave the site either directly or via
the stormwater system.
The following is provided at the site:
• Bunding and spill containment is provided for the following areas on the site:
- Plastic Storage and Densification Area;
- Tank Farm; and
- Process Modules.
• Runoff generated in potentially contaminated areas of the site, such as the main process
areas, will be contained onsite in bunded areas and processed through the waste water
treatment plant (WWTP). The transfer of accumulated water within these potentially
contaminated portions of the site to the WWTP is a manual operation.
• The main process area is covered by a roof minimising the potential for accumulation of
stormwater within the area.
• The tanker loading area is located on a hardstand with the rain water runoff reporting to
skim pits in the main processing area. The fuel residue from the pits is recovered and sent
to the rework tank for further processing.
• All traffic areas on the site are sealed concrete and stormwater reports to the first flush
system.
• The first flush system separates contaminants from the stormwater before discharge into
the municipal storm water system. The first flush system is described in detail in Section
3.9.2.
The FMEA, as detailed in Appendix A, identified two main failure cases which could lead to
contaminated runoff from the site:
• Failure of the spill containment areas (i.e. bund failure); and
• Failure of the first flush system.
A failure of the water treatment plant was not carried forward for assessment as the transfer of
contaminated stormwater from the bunded areas for treatment is a batch operation. Transfer to
the WWTP will not proceed if the WWTP is unable to treat the contaminated water.
5.3.1 Spill Containment Failure

The bunded areas at the site are to be designed in accordance with AS1940-2004 [Ref 5]
requirements including capacity, construction, drainage provisions, and bund wall penetrations. The
causes identified resulting in a failure of the spill containment areas provided at the site are a loss
of integrity of the bund surface, bund walls and around any bund wall penetration points.
A loss of spill containment integrity may result in stormwater contaminated with hydrocarbon
liquids draining to a drain point and entering the first flush system. The first flush system will capture
the release allowing for appropriate treatment of the stormwater.
If a vessel failure or major spill within the bund was to occur while the bund integrity was
compromised there is the potential for large volumes of hydrocarbon liquid to enter the first flush
system.

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The integrity of the spill containment provisions at the site is managed through routine inspections
and preventative maintenance.
5.3.2 First Flush System Failure

The first flush system process the first 15mm of rainfall from a rain event to remove any sediment
or oil that may be present before discharge. A failure of the system may result in the carryover of
contaminants to the municipal stormwater system.
The FMEA, as detailed in Appendix A, identified that primary causes for a failure to capture the first
15mm of rain fail in the first flush system are:
• Human Error – not emptying first flush system after previous rain event;
• Blockage in the first flush system;
• Diverter valve failure; and
• Blockage of surface drains.
The monitoring of stormwater at the site is covered by the FOY Stormwater Management Policy
which includes:
• Weekly Inspections of the first flush system;
• General site housekeeping; and
• Emptying first flush system after a rain event.
The checks associated with the first flush system are critical; therefore, FOY should consider
adopting a formalised ‘Check Sheet’ with appropriate levels of sign off to ensure the first flush
system is being adequately monitored.
5.4 Critical Infrastructure for Prevention of Vessel Rupture

A detailed hazard identification was undertaken as a part of the Preliminary Hazard Analysis (PHA)
for this project [Ref 1], identifying all the potential loss of containment scenarios. The hazard
identification word diagrams are given in Appendix B. The primary causes of a loss of containment
can be defined as either a failure of the integrity of the equipment from corrosion, mechanical
impact, flange leak etc., or an operation deviation such as a vessel overpressure or tank overfill
event.
A high-level summary of the measures adopted to prevent a loss of containment of hazardous
material for each of plant areas is provided below:
Site Wide
• Plant and equipment designed to codes and standards.
• Corrosion allowances.
• Equipment material selection based on the process conditions.
• Commissioning checks.
• Integrity inspections.
• Preventative maintenance.
• Controlling process within ‘Operating Envelopes’.
• Standard Operating Procedures.

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• Trained and competent Operators.

Raw Materials Handling:
• Raw materials stored within a warehouse building.
• Raw material inventory management.
Kiln Depolymerisation:
• Fugitive emission control as per Section 5.1.
• Raw material quality checks and procedures to ensure no non-compatible materials such
as PVC enter the process.
Tank Farm:
• Tank farm is designed in accordance with AS1940-2004.
• Tank farm is fully bunded.
• LPG Vessel designed in accordance with AS1596
• Stormwater from the bunds is managed as per Section 5.3.
Diesel/Petrol Loading Bay:
• Scully overfill protection system.
• Loading hose inspections.
• Tanker drive-away protection.
• Loading bay provided with spill containment.
• Stormwater from the loading bay is managed as per Section 5.3.
The consequence of a fire or explosion events at the site are detail in the PHA [Ref 1] and include:
• Pool fires with the tank farm bund;
• Tank top fires;
• Jet tires;
• Flash fires;
• Vapour cloud explosions (VCEs); and/or,
• Boiling liquid expanding vapour explosions (BLEVEs).
The quantitative risk assessment (QRA) undertaken as part of the PHA found the facility complied
with the risk criteria as stipulated in the Hazardous Industry Planning Advisory Paper (HIPAP) 4: Risk
Criteria for Land Use Safety Planning [Ref 2] of the NSW Department of Planning and Environment.
5.5 Critical Infrastructure for Control of Fires and Explosions

In the event of a loss of containment of hydrocarbon liquid or vapour, as described in Section 5.4,
there is the potential for a fire or explosion if ignition occurs. The fire prevention, detection and
mitigation measures provided in the design for the FOY Plastics to Liquid Fuel facility are detailed
above in Section 3.9.3 and include the following:
• Ignition Control;
• Spill Control (Bunding);

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• Flammable Gas Detection;

• Flame Detection;
• Fire Fighting Equipment; and
• Emergency Response Plan.
The reliability and adequacy of the proposed fire prevention, detection and mitigation measures are
to be assessed in detail in the site Fire Safety Study (FSS), which will be undertaken later in the design
process once the design has been further advanced. The FSS will include an assessment of the
cooling water requirements as per AS 1940-2004 Appendix J, and be prepared in line with the
requirements of the NSW Hazardous Industry Planning Advisory Paper (HIPAP) No. 2 ‘Guidelines for
Fire Safety Study’ January 2011.

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6 FINDINGS AND RECOMMENDATIONS

6.1 Findings
An assessment was undertaken for the proposed FOY Plastics to Liquid Facility in the Australian
Capital Territory (ACT) to assess ‘Critical Infrastructure Failure’ based on the following as identified
by the ACT EPA.
- Control of fugitive emissions from process equipment and storage vessels;
- Control of tail gas emissions from the process;
- Prevention of the rupture or loss of containment of gas or liquid vessels
- Prevention or control of fire or explosion in the facility; and
- Prevention of contaminated stormwater exiting the facility.
Based on the information provided, the design has considered the effect of a failure of the critical
infrastructure, as defined above, and sought to include appropriate mitigations in the event of their
failure.
As the project is in early stages of ‘detailed’ design, much of the project documentation is still being
complied, with various study recommendations being incorporated into the design on an ongoing
basis.
6.2 Recommendations
The following recommendations have been made:
1. A Safety Integrity Level (SIL) assessment be undertaken to assess the reliability of the Fugitive
Emission Control protective functions.
2. A SIL assessment be undertaken to assess the reliability of the cyclone combustor burner
management system interfaces with the plant PLC and the diverter valve functionality to
ensure the risk is adequately reduced.
3. The final design of the pilot gas supply system was not available at this stage of the project;
however, it is recommended that the pilot gas supply be suitably independent of the process
to ensure a loss of pilot gas will not result from any plant upset or emergency condition. This
may include redundancy via an LPG cylinder backup supply on loss of pilot gas.
4. The checks associated with the first flush system are critical; therefore, FOY should consider
adopting a formalised ‘Check Sheet’ with appropriate levels of sign off to ensure the first flush
system is being adequately monitored.
5. A Fire Safety Study should be undertaken to assess the adequacy of the fire prevention,
detection and mitigation provisions for the facility once the design has further developed.
6. Ensure a Hazard and Operability (HAZOP) Study is undertaken once the detailed design has
been developed.
7. Consider undertaken a full FMECA for the operation at the facility once the detailed design
has been developed.

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7 REFERENCES
1. Arriscar Pty Limited, November 2016, Non-Recyclable Plastic to Liquid Fuel Processing
Facility Preliminary Hazard Analysis.
2. Department of Planning and Environment, January 2011, Hazardous Industry Planning
Advisory Paper (HIPAP) No. 4: Risk Criteria for Land Use Safety Planning.
Advisory Paper (HIPAP) No. 6: Hazard Analysis.
Advisory Paper (HIPAP) No. 2: Fire Safety Study Guidelines.
5. Australian Standard AS1940–2004: The Storage and Handling of Flammable and
Combustible Liquids
6. Btola, November 2016, Critical Infrastructure Failure Report, Report Number 2620.10753-
SO2.
7. FOY Group Limited, July 2016, Non-Recyclable Plastic to Liquid Fuel Processing Facility
Environmental Impact Statement.

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Appendices

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Appendix A FMEA Worksheets

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Functional
No. System Equipment Failure Mode Failure Cause Local Effects Global Effects Detection Method Provisions & Safeguards
Description
1 Catalytic Reactor Slide Gate Provides a seal Failure to seal Failure of Potential for Potential for a 1) RAMs fails closed
between the plug hydraulic air ingress into flammable 2) 2 Slide Gates
screw and the system the kiln mixture within operating in series
depolymerisation the kiln resulting 3) Plug screw seal
module preventing a in a confined
hydrocarbon release explosion
or air ingress via the
Connection Failure of link Potential for Potential for a 1) Solenoid valves are fail
feedstock conveyer
Failure between the hydrocarbon release of closed and will close in
ram and the gas release flammable the event of PLC
slide from kiln material and a communications loss
fire if ignited 2) Plug screw seal
Configuration Incorrectly Potential for Potential for a 1) Solenoid valves are fail
failure configured PLC hydrocarbon release of closed and will close in
gas release flammable the event of PLC
from kiln material and a communications loss
fire if ignited 2) PLC configuration
checks
3) Access to PLC logic and
configurations is
password protected
4) Plug screw seal

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Functional
Description
2 Catalytic Reactor Plug Screw Seal Provides a seal for Failure to seal Plug screw Potential for Potential for a Loss of current on 1) Slide Gates in series
the drive failure air ingress into flammable Plug Screw dive 2) Kiln under slight
depolymerisation the kiln mixture within raises and alarm, negative pressure
module preventing a the kiln resulting with operator
hydrocarbon release in a confined intervention
or air ingress via the explosion
feedstock conveyer
Failure to seal Plug screw flap Potential for Potential for a - 1) Slide Gates in series
failure hydrocarbon release of 2) Kiln under slight
gas release flammable negative pressure
from kiln material and a
fire if ignited
- No feedstock Potential for Potential for a Feed hopper level 1) Slide Gates in series
hydrocarbon release of alarm 2) Kiln under slight
gas release flammable negative pressure
from kiln material and a
fire if ignited
3 Packed Gland Provide a seal Failure to seal Wearing Small leaks at NA Visual Inspection 1) Material select for the
Seals rotating equipment the gland seal during shift duty
2) Preventative
Maintenance
Failure to seal Loss of stuffing Small leaks at NA Visual Inspection 1) Material select for the
box gland the gland seal during shift duty
2) Preventative
Maintenance

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Functional
Description
4 Fugitive emission Collection Fan Provides suction for Fan Failure Fan stops/fails Potential Potential to 1) Pressure 1) Controlled plant
collection system the fugitive emission fugitive exceed monitoring of the shutdown initiated on
system emission to allowable fugitive emission loss of vacuum in fugitive
atmosphere at fugitive system via PLC emission system
fume hood emissions levels 2) Alarm on loss of
locations Fugitive Emissions Fan
Loss of power Potential Potential to 1) Pressure 1) Controlled plant

(local to the fugitive exceed monitoring of the shutdown initiated on
fan) emission to allowable fugitive emission loss of vacuum in fugitive
atmosphere at fugitive system via PLC emission system
fume hood emissions levels 2) Alarm on loss of
locations Fugitive Emissions Fan
5 System ducting Provides pathway for Ducting failure 1) Mechanical Excess Air Reduction in 1) Pressure 1) Controlled plant
collection of fugitive impact ingress into fugitive monitoring of the shutdown initiated on
emissions 2) corrosion fugitive emissions fugitive emission loss of vacuum in fugitive
emissions system system via PLC emission system
system performance 2) Alarm on loss of
Fugitive Emissions Fan
6 Cyclone burner Vapour from fugitive Cyclone burner Cyclone burner Fugitive Fugitive Module Status 1) If cyclone burner has
emissions system is not operating trip emission emission Alarm tripped there is no heat
feed to the cyclone system flow hydrocarbon gas input into the reactor
burn continues into released from and hence no vapour
Cyclone burner the module generation
stack

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Functional
Description
7 Catalytic Reactor Pressure Maintain a slight Fails to sense Loss of Signal Potential for Increased Independent Module Shutdown on
pressure control Transmitter (on vacuum within the pressure (reads low) pressure pressure in Pressure loss of vacuum for more
discharge of catalytic reactor increase in system may Transmitter than 1 minute
Glycol Heat system result in a
Exchanger) release of
vapour from the
catalytic reactor
feed/ash
removal points
Fails to sense Loss of Signal Potential to Air ingress into Independent 1) 2 Slide Gates
pressure (reads high) create the catalytic Pressure operating in series
excessive reactor causing Transmitter 2) Plug screw seal
vacuum combustion
within the
reactor and
higher levels of
ash formation
8 Pressor Fails to control Controller fails Independent Module Shutdown on

controller failure pressure Pressure loss of vacuum for more
Transmitter than 1 minute

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Functional
Description
9 Catalytic Reactor Gas Compressor Compressors gas to Under Speed Compressor Potential for Increased Pressure Module Shutdown on
pressure control (including VSD) the desired pressure VSD failure pressure pressure in Transmitter on loss of vacuum for more
increase in system may system than 1 minute
system result in a
release of
vapour from the
catalytic reactor
feed/ash
removal points
Drive failure Compressor Potential for Increased 1) Fault Alarm on 1) Module Shutdown on
VSD failure pressure pressure in Loss of current to loss of vacuum for more
(trip) increase in system may compressor drive than 1 minute
system result in a 2) Pressure 2) Gas flow diverted to
release of Transmitter (PT emergency flare
vapour from the XXX) on system
catalytic reactor
feed/ash
removal points

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Functional
Description
9 Catalytic Reactor Gas Compressor Compressors gas to Mechanical Compressor Potential for Increased 1) Fault Alarm on 1) Module Shutdown on
pressure control (including VSD) the desired pressure failure VSD failure pressure pressure in Excessive current to loss of vacuum for more
(seize etc.) increase in system may compressor drive than 1 minute
release of Transmitter) on emergency flare
vapour from the system
catalytic reactor
feed/ash
removal points
Overspeed Compressor Potential to Air ingress into Independent 1) 2 Slide Gates

VSD failure create the catalytic Pressure operating in series
excessive reactor causing Transmitter 2) Plug screw seal
vacuum combustion
within the
reactor and
higher levels of
ash formation

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Functional
Description
9 Catalytic Reactor Gas Compressor Compressors gas to - Loss of Power Potential for Increased 1) Fault Alarm on 1) Module Shutdown on
pressure control (including VSD) the desired pressure pressure pressure in Loss of current to loss of vacuum for more
increase in system may compressor drive than 1 minute
release of Transmitter on emergency flare
vapour from the system
catalytic reactor
feed/ash
removal points
10 Hydrocarbon Cooling water Provides flow of Pump Pump Loss of cooling Increased 1) Flow Transmitter 1) PALL initiates Back-up
condensing system pump (PU1601) cooling water mechanical mechanical water to hydrocarbon with Alarm on PLC diesel cooling water
damage damage condensers build up in [FAL] pump
vapour phase 2) Pressure 2) Back-up diesel cooling
Transmitter with water pump 'Available' is
Alarm on PLC [PAH] a plant permissive in the
PLC. Plant will not run if
the back-up diesel
cooling water pump is
not 'Available'

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Functional
Description
10 Hydrocarbon Cooling water Provides flow of Pump failure Pump failure Loss of cooling Increased 1) Flow Transmitter 1) PALL initiates Back-up
condensing system pump (PU1601) cooling water (drive stops) (drive stops) water to hydrocarbon with Alarm on PLC diesel cooling water
condensers build up in [FAL] pump
Alarm on PLC [PAL] a plant permissive in the
the back-up diesel
not 'Available'
- Loss of Power Loss of cooling Increased 1) Flow Transmitter 1) PALL initiates Back-up
water to hydrocarbon with Alarm on PLC diesel cooling water
condensers build up in [FAL] pump
Alarm on PLC [PAL] a plant permissive in the
the back-up diesel
not 'Available'
11 Cooling Tower Provides cooling Inadequate Fouling within Reduced Inadequate Routine Cooling 1) Cooling water
water to a given cooling cooling tower thermal condensation of tower inspections condition monitoring
temperature to efficiency hydrocarbon 2) Chemical dosing of
ensure adequate within cooling within the cooling water
cooling in the tower condensers
condenser

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Functional
Description
11 Hydrocarbon Cooling Tower Provides cooling Inadequate Cooling tower Reduced Inadequate Cooling tower fan Operator Intervention on
condensing system water to a given cooling fan fails thermal condensation of stop alarm on PLC alarm
temperature to efficiency hydrocarbon
ensure adequate within cooling within the
cooling in the tower condensers
condenser
High ambient Reduced Inadequate - The cooling tower has
temperature thermal condensation of been designed for the
efficiency hydrocarbon expected weather
within cooling within the conditions at the site
tower condensers
12 Chilled Vent Provides chilled Pump Stops Glycol Pump Reduction in No adverse Temperature -
Condenser cooling water to a failure volatile effect - this will Transmitter on
given temperature to component not lead to an Chilled Vent
ensure adequate yield emission form Condenser coolant
cooling in the the plant inlet
condenser
System Failure Chiller failure Reduction in No adverse Temperature -
volatile effect - this will Transmitter on
component not lead to an Chilled Vent
yield emission form Condenser coolant
the plant inlet

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Functional
Description
13 Gas Destruction Cyclone To destroy any Burner Flame Burner Flame Potentially Potential for a 1) Flame Scanners 1) Cyclone combustor
Combustor excess vapours Out Out hazardous release of within burner unit flame out will initiate a
before release to material not hazardous shutdown of the module
atmosphere destroyed material to the 2) Gases from the
atmosphere module will be diverted
to an operating module
Burner Fuel air Possible flame Potential for a 1) Flame Scanners

management mixture ratio out or release of within burner unit
system failure control failure Inadequate hazardous
temperature material to the
reached for atmosphere
noxious
chemical
destruction

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Functional
Description
13 Gas Destruction Cyclone To destroy any High or low Fuel air Possible flame Potential for a Flue Gas Oxygen 1) PLC control fuel air
Combustor excess vapours oxygen in flue mixture ratio out or release of Sensors mixture ratio
before release to gas control failure Inadequate hazardous 2) Module shutdown if
atmosphere temperature material to the combustion conditions
reached for atmosphere not restored
noxious 3) Gas diverted to the
chemical emergency flare
destruction 4) Emission monitoring
of Module Final Stack
for: NOX, CO, Particles
(total), Total organic
compounds, SO2.
5) Continues monitoring
of Module Final Stack
for: Combustion
chamber temperature,
O2 Concentration, Stack
temperature, and water
vapour.
Total Loss Loss of Power Possible flame Potential for a Alarm on the PLC 1)PLC will initiate full
out or release of plant shutdown on loss
Inadequate hazardous of power
noxious material to the 2) PLC provided with UPS
chemical atmosphere backup
destruction 3) Flow diverted to the
Emergency Flare

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Functional
Description
14 Gas Destruction Module Diverter Diverts the flow Valve stuck Valve fails to Gas not Un-combusted Position switches -
Valve away from the change diverted to the hydrocarbon gas on the diverter
offline cyclone position other cyclone released from valve with position
combustor to the combustors the module proving alarm on
online cyclone stack the PLC
combustors
15 Flare Diverter Diverts the flow Valve stuck Valve fails to Gas not Un-combusted Position switches -
Valve away from the change diverted to the hydrocarbon gas on the diverter
cyclone combustor position Emergency released from valve with position
to the Emergency Flare the module proving alarm on
Flare stack the PLC
16 Emergency Flare Flare Pilot Maintain an ignited Loss of pilot gas Loss of supply Flare pilot light Unable to ignite 1)Flame detectors 1)PLC monitors flare
pilot light to ignite a extinguished full flare flow in on flare tip 2) Loss of flare pilot light
flow of hydrocarbons the event of a will result in a module
in the event plant upset shutdown
hydrocarbons are
diverted to the
emergency flare
Loss of spark Ignition failure Unable to Unable to ignite 1)Flame detectors 1)PLC monitors flare
ignite pilot full flare flow in on flare tip 2) Loss of flare pilot light
light the event of a 2) Igniter system will result in a module
plant upset failure alarm shutdown

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Functional
Description
17 Spill Containment Spill Provides Loss of integrity Crack in the Bund unable to Potential for a 1)Operator 1) Periodic Inspection of
Containment containment of a bund wall perform its release of Surveillance bunds
Bund hydrocarbon spill in intended hazardous 2) Preventative
the event of an function material to the Maintenance
unwanted release site 3) All drains outside of
the bunded areas report
to the first flush system
Loss of integrity Degraded bund Bund unable to Potential for a 1)Operator 1) Periodic Inspection of
surface perform its release of Surveillance bunds
intended hazardous 2) Preventative
function material to the Maintenance
site 3) All drains outside of
Loss of integrity Penetration Bund unable to Potential for a 1)Operator 1) Periodic Inspection of
failure perform its release of Surveillance bunds
intended hazardous 2) Preventative
function material to the Maintenance
site 3) All drains outside of

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Functional
Description
18 First Flush First Flush Tanks To collect the Human Error Operator fails First 15mm of Potential for any 1) Stormwater
surface runoff for to empty tank the current surface management policy to
the first 15mm of after previous rain event not contaminants to empty system after each
rain for any rain rain event collected flow into the rain event
event municipal 2) Operator training
stormwater 3) Weekly inspections
4) General housekeeping
to minimise potential for
contaminants
Line Blockage Build-up of First 15mm of Potential for any 1) Stormwater

material the current surface management policy to
rain event not contaminants to empty system after each
collected flow into the rain event
municipal 2) Operator training
stormwater 3) Weekly inspections
4) General housekeeping
to minimise potential for
contaminants
5) System design and line
sizes to minimise
blockages

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Functional
Description
First Flush Diverter Diverts the flow to Diverts to early Diverter stuck Portion of the Potential for any 1) Preventative
municipal first 15mm of surface maintenance of system
stormwater after runoff enters contaminants to 2) Weekly inspections
15mm of rain the municipal flow into the 3) General housekeeping
collected. stormwater municipal to minimise potential for
stormwater contaminants
4) Diverter valve design
Drain The drain is the Drain blockage Build-up of Runoff Potential for Visual Inspections 1) Housekeeping
collection point material accumulates runoff to spill 2) Weekly inspections in
which directs runoff on the surface beyond the site 3) Drain layout and
into the first flush and is not able surface gradient
system to be treated designed to keep runoff
onsite

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Appendix B Hazard Identification

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Hazard Identification Word Diagram

Processes: 1. Raw Material Handling
Nodes: 1. Transportation to site
Prevention Mitigation
Scenario Causes Consequence Recommendations Responsibility
Control Control
1.Spill of plastics in 1.MVA 1.Plastics fall to the road 1. Licensed Drivers 1. Clean up
transit
2. Service Supplier
Controls
3. Vehicle
inspections
2.Human Error - load not 1.Plastics fall to the road 1. Service Supplier 1. Clean up
secured Controls
2. Licensed Drivers
3. Vehicle
inspections
2.Truck fire 1.Fire on truck 1.Potential fire of plastic 1. Vehicle 1. Extinguishe
cargo inspections rs on site
2. Licensed Drivers
3. Service Supplier
Controls

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Processes: 1. Raw Material Handling

Nodes: 2. On site movements
Control Control
1.Fire in Plastics store 1.Local ignition sources 1.Fire in plastic s store 1. Ignition control
on site
2. Hazardous Area
Classification
3. PTW System
4. General House
keeping
5. Electrical
testing/ Tags
2.Fire escalation from 1.Fire in plastic s store 1. Hazardous Area 1.Ensure the plastics FOY
adjoining plant Classification store building is
designed to the
2. Ignition control
requirements set out
on site
in the building
3. Plastic store is assessment
within a
building and not
directly exposed
to a fire in the
plant

Page 50
Revision: A
Processes: 2. Plastics Processing

Nodes: 1. Plastic feed
Control Control
1.Air ingress into kiln 1.Failure of seal gates 1.Potential for oxygen 1. Auger makes a
increase in the kiln plug of plastic
sealing the
system from air
2.Potential for flammable 2. Oxygen will
mixture to form in the kiln combust
immediately
with HC
2.Contaminated feed 1.Excess PVC 1.PVC creates HCL in the 1. Feed stock 2.Ensure the feedstock FOY
kiln with potential for quality management
higher corrosion rates agreement with procedure adequately
supplier addresses the checks
for PVC and PET
2. Onsite feed
stock
monitoring and
rejection of
contaminated
feedstock
2.Excess PET 1.High LPG yield resulting in 1. Feed stock
low desired product yield quality
agreement with
supplier
2.PET catalyst (Antimini 2. Onsite feed
Dioxide) ends up in char stock
monitoring and

Page 51
Revision: A

Control Control
rejection of
contaminated
feedstock

Nodes: 2. CRM
Control Control
1.Release from Kiln 1.Flange/Fitting failure 1.Release of HC vapour to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
atmosphere selection and Study considers the
design to appropriate
relevant prevention/detection
standards measures for releases
from the process
2. Planned 2. Ignition
Maintenance
2.Potential for flash fire 1. Firewater
Program with
Deluge
weekly/monthly
system
checks (1month
per year
allocated for
each module)
2.Corrosion 1.Release of HC vapour to 1. Material 1. Ignition 4.Ensure the Fire Safety FOY
standards

Page 52
Revision: A

Control Control
2.Potential for flash fire 2. Planned 1. HAC measures for releases
Maintenance from the process
2. Firewater
Program with
Deluge
weekly/monthly
system
checks (1month
per year
allocated for
each module)
2.Release from Scrubber 1.Flange/Fitting failure 1.Release of HC vapour to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
from the process
Maintenance
2.Potential for flash fire 1. Firewater
Program with
Deluge
weekly/monthly
system
checks (1month
per year
allocated for
each module)
standards

Page 53
Revision: A

Control Control
2.Potential for flash fire 2. Planned 1. HAC measures for releases
2. Firewater
Program with
Deluge
weekly/monthly
system
checks (1month
per year
allocated for
each module)
3.Release from 1.Flange/Fitting failure 1.Release of HC vapour to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
fractionator atmosphere selection and Study considers the
from the process
Maintenance
2.Potential for flash fire or 1. Firewater
Program with
VCE Deluge
weekly/monthly
system
checks (1month
3.Potential for liquid release per year 1. Firewater
and pool fire allocated for Deluge
each module) system
2. Bunding
around
Modules

Page 54
Revision: A

Control Control
from the process
2.Potential for flash fire or 2. Planned 1. Firewater
VCE Maintenance Deluge
Program with system
weekly/monthly
3.Potential for liquid release 1. Bunding
checks (1month
and pool fire around
per year
Modules
allocated for
each module) 2. Firewater
Deluge
system
4.Release from Diesel 1.Flange/Fitting failure 1.Potential for liquid release 1. Material 1. Firewater 4.Ensure the Fire Safety FOY
Processing and pool fire selection and Deluge Study considers the
design to system appropriate
from the process
2. Planned 2. Bunding
Maintenance around
Program with Modules
weekly/monthly
checks (1month
per year
allocated for
each module)

Page 55
Revision: A

Control Control
2.Corrosion 1.Potential for liquid release 1. Material 1. Bunding 4.Ensure the Fire Safety FOY
and pool fire selection and around Study considers the
design to Modules appropriate
from the process
2. Planned 2. Firewater
Maintenance Deluge
Program with system
weekly/monthly
checks (1month
per year
allocated for
each module)
5.Release from Petrol 1.Flange/Fitting failure 1.Release of LPG to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
Processing atmosphere selection and Study considers the
from the process
Maintenance
Program with
VCE Deluge
weekly/monthly
system
checks (1month
each module) system

Page 56
Revision: A

Control Control
2. Bunding
around
Modules
2.Corrosion 1.Release of LPG to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
from the process
Maintenance
Program with
VCE Deluge
weekly/monthly
system
checks (1month
3.Potential for liquid release per year 1. Bunding
and pool fire allocated for around
each module) Modules
2. Firewater
Deluge
system
Processes: 3. Liquid Storage

Nodes: 1. Diesel Store
Control Control

Page 57
Revision: A

Control Control
1.Release of Diesel from 1.Vehicle impact with pipe 1.Potential for liquid release 1. Pipe bridge 1. HAC 5.Ensure vehicle access FOY
pipework bridge and pool fire design to site is restricted for
over height vehicles
to avoid contact with
structures
2. On-site Traffic 2. Ignition 6.Ensure the Fire Safety FOY
Management Control Study considers the
Plan firewater
3. Firewater
requirements for the
System on
site
Site
2.Flange Fitting Failures 1.Potential for liquid release 1. Material 1. Ignition
and pool fire selection and Control
design to
relevant
standards
2. Preventative 2. HAC
maintain
3. Firewater
System on
Site
2.Release of Diesel from 1.Vehicle impact with tank 1.Potential for liquid release 1. On-site Traffic 1. HAC 7.Ensure the tank farm FOY
storage tanks and pool fire Management bunding arrangement
Plan compiles with AS1940
2. Pipe bridge 2. Ignition
design Control

Page 58
Revision: A

Control Control
3. Bollards around 3. Firewater
the storage System on
vessel bund Site
4. Tank farm is
bunded
2.Flange Fitting Failures 1.Potential for liquid release 1. Preventative 1. Firewater
and pool fire maintenance System on
Site
2. Material 2. Ignition
selection and Control
design to
3. HAC
relevant
standards
3.Tank overfill 1.Potential for liquid release 1. Level control 1. Firewater 8.Ensure the storage
and pool fire system System on tanks have adequate
Site overfill protection
2. Ignition
Control
3. HAC
3.Release of Diesel 1.Vehicle impact with tank 1.Potential for liquid release 1. Pipe bridge
during tanker fill and pool fire design
2. On-site Traffic
Management
Plan

Page 59
Revision: A

Control Control
2.Flange Fitting Failures 1.Potential for liquid release 1. Preventative 9.Ensure the system FOY
and pool fire maintenance provides adequate
overfill protection of
2. Material
the product road
selection and
tankers
design to
relevant
standards
3.Overfill of tank road 1.Potential for liquid release 1. Procedures 9.Ensure the system FOY
tanker and pool fire provides adequate
the product road
tankers
4.Tanker drive away 1.Potential for liquid release 1. Procedures 10 Ensure adequate FOY
and pool fire . drive away
protection is
provided

Nodes: 2. Petrol Store
Control Control
1.Release of Petrol from 1.Vehicle impact with pipe 1.Potential for liquid release 1. Pipe bridge 1. HAC 5.Ensure vehicle access FOY
pipework bridge and pool fire design to site is restricted for
over height vehicles

Page 60
Revision: A

Control Control
to avoid contact with
structures
2. On-site Traffic 2. Ignition 6.Ensure the Fire Safety FOY
Management Control Study considers the
Plan firewater
3. Firewater
requirements for the
System on
site
Site
2.Flange Fitting Failures 1.Potential for liquid release 1. Material 1. Ignition
and pool fire selection and Control
design to
relevant
standards
2. Preventative 2. HAC
Maintenance
3. Firewater
System on
Site
2.Release of Petrol from 1.Vehicle impact with tank 1.Potential for liquid release 1. On-site Traffic 1. HAC 7.Ensure the tank farm FOY
storage tanks and pool fire Management bunding arrangement
Plan compiles with AS1940
2. Pipe bridge 2. Ignition
design Control
3. Bollards around 3. Firewater
the storage System on
vessel bund Site

Page 61
Revision: A

Control Control
4. Tank farm is
bunded
2.Flange Fitting Failures 1.Potential for liquid release 1. Preventative 1. Firewater
and pool fire Maintenance System on
Site
2. Material 2. Ignition
selection and Control
design to
3. HAC
relevant
standards
3.Tank overfill 1.Potential for liquid release 1. Level control 1. Firewater 8.Ensure the storage
and pool fire system System on tanks have adequate
Site overfill protection
2. Ignition
Control
3. HAC
3.Release of Petrol 1.Vehicle impact with tank 1.Potential for liquid release 1. Pipe bridge
during tanker fill and pool fire design
2. On-site Traffic
Management
Plan
2.Flange Fitting Failures 1.Potential for liquid release 1. Preventative 9.Ensure the system FOY
and pool fire Maintenance provides adequate

Page 62
Revision: A

Control Control
2. Material overfill protection of
selection and the product road
design to tankers
relevant
standards
3.Overfill of tank road 1.Potential for liquid release 1. Procedures 9.Ensure the system FOY
tanker and pool fire provides adequate
the product road
tankers
4.Tanker drive away 1.Potential for liquid release 1. Procedures 10 Ensure adequate FOY
and pool fire . drive away
protection is
provided

Nodes: 3. LPG Store
Control Control
1.Release from LPG 1.Flange/Fitting failure 1.Release of LPG to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
vessels atmosphere selection and Study considers the
from the process
2. Ignition

Page 63
Revision: A

Control Control
2.Potential for flash fire or 2. Planned 1. Firewater
VCE Maintenance Deluge
Program with system
weekly/monthly
3.Potential for liquid release 1. Firewater
checks (1month
and pool fire Deluge
per year
system
allocated for
each module) 2. Bunding
around
Modules
2.Overfilling of vessel 1.Release of LPG to 1. HAC
atmosphere
2. Ignition
VCE Deluge
system
Processes: 4. LPGs
Nodes: 1. Processing
Control Control
1.Release from LPG 1.Flange/Fitting failure 1.Release of LPG to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
Processing atmosphere selection and Study considers the
standards

Page 64
Revision: A

Control Control
2. Planned 2. Ignition measures for releases
Program with
VCE Deluge
weekly/monthly
system
checks (1month
each module) system
2. Bunding
around
Modules
2.Corrosion 1.Release of LPG to 1. Material 1. HAC 4.Ensure the Fire Safety FOY
from the process
Maintenance
Program with
VCE Deluge
weekly/monthly
system
checks (1month
3.Potential for liquid release per year 1. Bunding
and pool fire allocated for around
each module) Modules

Page 65
Revision: A

Control Control
2. Firewater
Deluge
system

Page 66
Revision: A
Processes: 5. General
Nodes: 1. Sabotage
Control Control
1.Intentional Miss 1.Incompatibly material 1.Potential for fire or 1. CCTV 3.Consider suitable FOY
use/Terrorism brought on site (i.e. explosion checks of people and
2. Motion sensors
fertiliser) vehicles before
on the
granting access to the
perimeter
site
3. perimeter fence
with cyclone
barbwire
4. perimeter
lighting
5. Police Checks
for all staff
6. Car parking is
offsite
7. Contractor
management

Page 67
Revision: A

Appendix D CIF Report PDF

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Appendix D CIF Report PDF

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Non-Recyclable Plastic to Liquid Fuel

For FOY Group Limited

Doc. No.: J-000241-REP-FMEA

Document History and Authorisation

4 Systems and Equipment for FMEA................................................................................................. 21

6 Findings and Recommendations .................................................................................................... 29

Doc Number: J-000241-REP-FMEA

Appendix B Hazard Identification.................................................................................................. 48

Doc Number: J-000241-REP-FMEA

Doc Number: J-000241-REP-FMEA

1.3.1 Scope of Analysis

Doc Number: J-000241-REP-FMEA

- Prevention or control of fire or explosion in the facility; and

1.3.2 Scope of Facilities and Operations

Doc Number: J-000241-REP-FMEA

2.1 FMEA Methodology

Doc Number: J-000241-REP-FMEA

Figure 1 Overview of FMEA Process

Doc Number: J-000241-REP-FMEA

2.2 Generic Failure Modes

• Erroneous input (increased / decreased)

Doc Number: J-000241-REP-FMEA

3.2 Facility Overview

Doc Number: J-000241-REP-FMEA

Doc Number: J-000241-REP-FMEA

Figure 3 Site Layout

Doc Number: J-000241-REP-FMEA

3.3 Plastic Storage Area and Extruder

3.4 Processing Area

Doc Number: J-000241-REP-FMEA

Figure 4 Process Flow Diagram

3.5 Tank Farm

Doc Number: J-000241-REP-FMEA

3.6 Tanker Loading Area

Doc Number: J-000241-REP-FMEA

3.9 Proposed Prevention and Mitigation Control Measures

3.9.1 Spill Prevention and Mitigation

3.9.2 Stormwater system

Doc Number: J-000241-REP-FMEA

3.9.3 Fire Prevention, Detection and Mitigation

3.9.4 Safety Management System

Doc Number: J-000241-REP-FMEA

4 SYSTEMS AND EQUIPMENT FOR FMEA

Doc Number: J-000241-REP-FMEA

5 ASSESSMENT OF CRITICAL INFRASTRUCTURE

5.1 Control of Fugitive Emissions

Doc Number: J-000241-REP-FMEA

5.2 Control of Tail Gas Emissions

5.2.1 Excess Tail Gas

5.2.2 Cyclone Burner Failure

Doc Number: J-000241-REP-FMEA

5.2.3 Emergency Flare Failure

5.3 Containment of Contaminated Stormwater

Doc Number: J-000241-REP-FMEA

5.3.1 Spill Containment Failure

Doc Number: J-000241-REP-FMEA

5.3.2 First Flush System Failure

5.4 Critical Infrastructure for Prevention of Vessel Rupture

Doc Number: J-000241-REP-FMEA

• Trained and competent Operators.

5.5 Critical Infrastructure for Control of Fires and Explosions

Doc Number: J-000241-REP-FMEA

• Flammable Gas Detection;