Australian Capital Territory Non-Recyclable Plastics to Fuel Facility
FOY Group Limited (“FOY”), is in the process of acquiring the non-recyclable waste plastics to fuel technology from Integrated Green Energy Limited (“IGE”). As part of its strategic roll out FOY has identified the ACT as the ideal location to design and construct its first facility. FOY plans to operate this facility in addition to the 50 tonne per day module it will be acquiring from IGE located at Berkeley Vale, NSW. This 5th generation technology represents a unique opportunity for communities to divert non-recyclable waste plastics from landfill and convert them into high quality road ready fuels that meet Australian Petrol and Diesel Standards.
FOY has been working closely with the ACT Government to ensure all environmental and planning requirements are met. In April 2016 FOY lodged an Application for a Scoping Document. Based on the information requested by the relevant ACT Government departments following the assessment of this document, FOY complied a Draft Environmental Impact Statement (“EIS”) which was submitted to the ACT Environment and Planning Directorate. To access the full document and associated appendices via the Environment and Planning Directorate – Planning website, please click here.
As part of the approvals procedure, FOY held a community engagement evening at Rose Cottage on 30 August 2016. Reproduced below is the information flyer distributed to residents and surrounding businesses prior to the event:
Interview with the Canberra Times
The Draft EIS is currently in the process of public consultation. As part of that consultative process, FOY spoke with Mr Andrew Brown of The Canberra Times to discuss the project. Listed below are 12 written questions that Mr Brown asked and the responses FOY provided him in advance of the face to face interview:
1: Why was the site in Hume chosen? Was it possible to have chosen a site that was further away from residents?
The ACT government has zero recoverable waste to landfill policy as per the “ACT Waste Management Strategy 2011-2025”. This is closely aligned with the philosophy of our business. The site was chosen as it meets FOY’s requirements in that it has industrial zoning, is of an adequate size, is centrally located between Sydney and Melbourne and is in close proximity to a major highway. The industrial site was released to the market by the LDA through a tender process. The land release is the result of several years of planning and development undertaken by the ACT Government, in order to prepare this industrial estate for market.
FOY’s proposal is consistent with the zoning of the land for industrial purposes, and consistent with the Crown Lease which was released as part of the sale package for the site. FOY has spent large amounts of time and money ensuring that the processing of end of life plastics into diesel and petrol will have no negative impacts on the environment and community. Therefore, the distance to residential areas, while a factor for consideration, is off-set by the very low emissions. For comparative purposes, the emissions from our plant will be less than the emissions from a single home wood-fire which sits within residential areas. We appreciate via the consultation meeting that the local residents have not always had good experiences with this industrial zoned land in the past however we are confident that our contribution will be positive.
2: Are there any other similar facilities in other states or territories?
FOY operates a facility using the same equipment as proposed for the Hume site in Berkeley Vale NSW. During the period of operation, management is happy to report no environmental incidences and zero complaints from the community regarding the operation of the facility. It should be noted that the residential community in NSW are within 0.703 km of the Berkeley Vale facility which is nearly half the half the distance of the closest residents to the Hume facility, which is 1.32 km.
3: What is being done to alleviate concerns that nearby residents may have surrounding the project?
FOY has engaged an external expert in this area – Purdon Planning – a local company whose role is to assist in identifying and understanding community concerns and ensuring appropriate channels of communication are established. Stakeholder consultation has recently commenced – we are at the beginning of the consultation process, coinciding with release of the draft EIS for public comment. Our team is gathering information from the community and key stakeholders in order to understand the concerns that may exist. This will allow FOY to address any issues as the consultation process is progressed. Following the community meeting on 30 August 2016, Purdon Planning and FOY are working through all the comments and issues received from the community so that we are able to response to individual issues in a considered and effective manner.
There are also statutory processes that will allow for community comment on this proposal including the current EIS process, as well as the Development Application process.
4: If the site is running 24/7, with trucks also using the site until 10pm at night, how much noise and emissions from the site will residents have to put up with?
The traffic impacts are considered to be minimal, and not unreasonable in the context of an existing industrial park and the proximity to the Monaro Highway. It is expected that only 12 truck movements will occur each day (6 in 6 out). The logistics plan of the operation which incorporates maximum efficiencies, minimum penalty rate and minimum impacts on the community will result in the majority of truck movements being between 8am and 4 pm in the normal course of business. Further, the majority of these truck movements will be on business days with weekends and public holidays having lower delivery and pick-up activity.
5: If the site can burn 200 tonnes of plastic into 170 tonnes of fuel, what is being done with the other 30 tonnes that is being burned off?
The site / process will NOT burn plastic.
The facility converts the end-of-life, non-recyclable plastic into fuel which meets the Australian diesel and petrol standards. In fact the fuel is of such high quality that it meets Euro 4 and Underground Mining fuel specifications that have lower burn emissions than is currently used in vehicles. Some of this fuel may be used in the Canberra area to displace imported diesel and petrol but no more fuel will be utilised in vehicles as a result of the operation of the facility. In fact, if the fuel from the Hume site is utilised in Canberra, as planned, overall emissions in the Canberra region will reduce.
The other 30 tonnes/day is not burned off. The 30 tonnes/day of other material does not leave the process. It is LPG product which is then combusted to provide the necessary heat for the production process. The combustion of LPG from energy is recognised as being one of the cleanest sources of heating, especially when combined with FOY’s unique patented technologies.
6: What safety procedures are in place for workers inside the factory who work near the emissions?
All emissions and emission control devices from the facility will be constantly monitored to ensure there are no safety concerns. No additional safety equipment outside of any industrial plant operation (such as high-vis clothing, safety boots, hard hats and safety glasses) is required to be worn by workers. We have not had any process related safety issues as a result of several years of construction or operation for any employee or contractor at a FOY site.
7: Technical representatives at community meetings have told residents that there is a low fire risk at the site, but the EIS states the risk of this is very high. Why is this the case? Is the risk being underplayed?
The risk of fire originating in the site are minimal.
However, the site is adjacent to grassland and therefore the risk of bushfire incident originating outside the site was assessed to be high by an independent consultant. FOY are not downplaying this risk at all and have fire mitigation strategies including, full foam deluge systems on the plant and perimeter sprinklers to mitigate bushfire impact.
8: There are also concerns that the wrong wind model was used in the EIS for pollution, with flat land at sea level used in the model. Why is this the case?
FOY has consulted with independent experts in this field who state that the modelling technique used is the best available for the site. The emissions utilised in generating the model are a worst case scenario which are an order of magnitude above those measured in our actual operations at Berkeley Vale. The emissions data at our current operations at Berkeley Vale are mapped against the model parameters below.
|Compound||Level used in Air Quality Modelling||Actual Levels as measured at existing BKV Facility|
|Particulates (TSP)||50 mg/m3||0.77 mg/m3|
|Sulphur Dioxide||1000 mg/m3||< 2.9 mg/m3|
|Oxides of Nitrogen||350 mg/m3||135 mg/m3|
|Carbon Monoxide||125 mg/m3||24 mg/m3|
|Volatile Organic Compounds (VOC)||40 mg/m3||< 0.9 mg/m3|
|Combustion Temperature||Regulation of NSW EPA Group 6 emission is > 1100 degrees C||Actual measured temperature is > 1400 degrees C|
Due to the fact that there are no heavy metals or halogens present in the fuel source as will be the case with the ACT facility, heavy metals, dioxins and Furans are not measured. In consultation with the ACT EPA we have agreed to measure these pollutants in the Canberra Facility and we remain confident that the levels will be zero. It can clearly be seen that our actual emissions from our current site are well below the industry standard.
9: What steps are in place at the site to prevent air pollution?
Please note the actual air emissions at our Berkley Vale site are well below acceptable levels as specified by the NSW EPA.
Emissions from the plant are low because FOY has instituted European Best Available techniques in order to prevent air pollution including:
- The utilisation of cyclone combustor technology:
- To combust any noxious compounds at over 1400 degrees;
- To provide a residence time of over 2 seconds; and
- To provide rapid quench via exhaust gas recirculation to quickly move through formation zones.
- Fugitive emission collection and combustion;
- Chilled final condenser sets;
- Redundant diesel cooling water pumps; and
- Emission monitoring equipment.
10: What is the environmental effect of a factory such as this by converting plastic into fuel?
The fundamental focus of our company is to make a positive impact on the environment. Our mission and vision statements are below.
To remove from the environment all harmful end-of-life plastics that would otherwise go to land-fill or pollute our landscape and waterways by converting the plastic to a valuable resource. To develop sustainable and renewable energy sources that can be used to support our lifestyles whilst protecting the future environment on our planet. To build a bridge between commerce, governments, families and environmentalists via practical, commercial, environmentally positive solutions.
A world in which no plastics pollute the planet and where renewable energy sources are maximised.
A world in which commerce, governments, families and environmentalists live in harmony and work towards the common goal of building a sustainable system of environmental protection that supports our current life-styles and benefits us all.
That is, the company has a zero harm policy and expects no negative environmental effect in the Canberra area. We expect a positive environmental effect in other areas as we reduce the amount of plastic being dumped into landfill and reduce the consumption of fossil fuels via crude oil extraction.
11: What is the estimated cost of the project?
The establishment of the plant represents a $15 million development.
The ACT plant will generate approximately 30 operations staff on an ongoing basis. These jobs will range from highly skilled to unskilled labour.
The annual operations wages bill will be approximately $3 million per annum.
That is, in the first year alone we will have injected $18 million to the ACT economy before any multiplier effects. Applying a multiplier effect of 5 to the operations wages alone (assuming the employees spend 80% and save 20%) this will result in an injection of $15 million per annum across the ACT.
12: Are contracts already in place for plastics to be taken to the factory and fuel taken away from it?
Yes. FOY has organised back to back contracts including the supply of clean baled plastics to be delivered and Australian standard fuels to be taken away to customers.
Community Forum and Frequently Asked Questions
On 30 August 2016 FOY held a community forum for residents and businesses, with 69 guests in attendance. Two FOY Directors presented on the project and answered queries from those in attendance. A set of Frequently Asked Questions, based on questions raised during this meeting and subsequent correspondence, which has been developed by FOY in response to those queries, can be found by clicking here.
FOY is finalising its Development Application (“DA”), pursuant to the ACTPLA requirements, and concurrently addressing legislative requirements which are enforced by the ACT EPA in obtaining relevant Environmental Authorisations.