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HAZOP STUDY REPORT OF THE TURBINE HYDRAULIC POWER UNIT, BOILER UPGRADE AND LOW NOX BURNERS AS PART

OF THE ERARING ENERGY POWER STATION UPGRADE PROJECT


Prepared for: Revision B Eraring Energy

Document Number: ERAPOW\12-B177

Prepared by: Karin Nilsson 14 July 2009

PO Box 248 Berowra Heights NSW 2082 Telephone: [02] 9985 1056 Facsimile: [02] 9427 7851 Email: Planager@bigpond.net.au

HAZOP Study Report of the Turbine Hydraulic Power Unit, Boiler Upgrade and Low NOx Burners as Part of the Eraring Energy Power Station Upgrade Project

Acknowledgment
The author would like to thank the HAZOP review team and in particular Ian OBrian, Phil Fenney, Steve Shawcross, Graeme Hankin and Frank Mieszala for organising the HAZOP Studies and providing input and reviews of minutes and report.

Disclaimer
This report was prepared by Planager Pty Ltd (Planager) as an account of work for Eraring Energy. The material in it reflects Planager's best judgement in the light of the information available to it at the time of preparation. However, as Planager cannot control the conditions under which this report may be used, Planager and its related corporations will not be responsible for damages of any nature resulting from use of or reliance upon this report. Planager's responsibility for advice given is subject to the terms of engagement with Eraring Energy.

Rev A B

Date 19/06/2009 14/07/2009

Description Draft for Comment Final Report

Prepared By Karin Nilsson Karin Nilsson

Authorised By Frank Mieszala Frank Mieszala

HAZOP Study Report Of The Turbine Hydraulic Power Unit, Boiler Upgrade And Low Nox Burners As Part Of The Eraring Energy Power Station Upgrade Project

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CONTENTS
1 INTRODUCTION .............................................................................................. 6 1.1 1.2 1.3 1.4 1.5 Background...................................................................................... 6 Aim of This Report .......................................................................... 6 Location of EPS ............................................................................... 7 Project Description.......................................................................... 7 Scope of HAZOP Study ................................................................... 7

1.5.1 Boiler Upgrade................................................................................... 8 1.5.2 Turbine Hydraulic Power Supply ....................................................... 8 1.5.3 Low NOx Burners ............................................................................... 8 2 METHODOLOGY ............................................................................................. 9 2.1 2.2 2.3 2.4 3 Introduction...................................................................................... 9 Details of the HAZOP Study Procedure ......................................... 9 HAZOP Study Guidewords ........................................................... 10 Risk Ranking Tools ....................................................................... 12

RESULTS AND RECOMMENDATIONS............................................................... 13 3.1 3.2 Presentation of Risk Results ........................................................ 13 Risk Levels of the Boilers Design ................................................ 14

3.2.1 Level 4 Risks Boilers ....................................................................... 14 3.2.2 Level 3 Risks Boilers ....................................................................... 15 3.2.3 Level 2 and Level 1 Risks Boilers .................................................... 18 3.3 Risk Levels of the Turbine Hydraulic Power Unit Design .......... 18

3.3.1 Level 4 Risks Hydraulic Power Unit ................................................. 18 3.3.2 Level 3 Risks Hydraulic Power Unit ................................................. 18 3.3.3 Level 2 and Level 1 Risks Hydraulic Power Unit ............................. 19

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3.4

Risk Levels of the Low NOx Burner Design ................................. 19

3.4.1 Level 4 Risks Low NOx Burners....................................................... 19 3.4.2 Level 3 Risks Low NOx Burners....................................................... 19 3.4.3 Level 2 and Level Low NOx Burners ................................................ 19 3.5 Risk Profile of Plant Assuming HAZOP Recommendations in Place ........................................................................................................ 20 4 5 CONCLUSION............................................................................................... 21 REFERENCES ............................................................................................ 222

LIST OF APPENDICES
Appendix 1 HAZOP Study Minutes Appendix 2 Approval as HAZOP Leader Appendix 3 Eraring Energy Risk Tools

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REPORT
PROJECT TITLE: LOCATION: HAZOP MINUTES: HAZOP Leaders: Power Station Upgrade Project Eraring Energy Power Station. Appendix 1 Karin Nilsson (DoP Approved) Mark Wyburn (Eraring Energy, second half day of Boiler HAZOP. Methodology used and outcome reviewed by Karin Nilsson) HAZOP SCOPE AND DATES FOR STUDY: Boiler Upgrade 8 April and 5 May 2009 (1 days)

Turbine Hydraulic Power Supply 23 March 2009 (one day) Low NOx Burners 22 April 2009 (one day) RECORD OF ATTENDANCE Name Company Position

Boiler Upgrade Ian OBrian Ray Ansell Chris Brucki Shaun Edwards Gary Craig Phil Fenney Mark Wyburn (part time) Charlie Grima Eraring Energy Eraring Energy Eraring Energy Eraring Energy Eraring Energy Eraring Energy Eraring Energy Aurecon Project Manager, Boiler Upgrade Project Senior Tradesman Boiler Team Leader and Asset Management Project Change Manager Project Manager, CCP Project Project Manager, Low NOx Burners Chemical Asset Team Leader Boiler Operations Consultant

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RECORD OF ATTENDANCE Turbine Hydraulic Power Unit Steve Shawcross Graham Hankin Phil McWilliam Daniel McNally Keith Clark Ian Dawson Steve Wheeler Steve Gambrill (part time) Gemma Keith Low NOx Burner Phil Fenney Steve Wheeler Chris Brucki John Harris Tarkel Larson Kenneth Tichy Meg Trewhella Eraring Energy Eraring Energy Eraring Energy Eraring Energy Siemens Siemens Eraring Energy Project Manager, Low NOx Burners Operations Engineer Boiler Team Leader and Asset Management Plant Owner Field Services Manager Project Manager, Low NOx Burners Secretarial support Eraring Energy Eraring Energy PPI DPPA Rep Eraring Energy Eraring Energy Eraring Energy Eraring Energy Eraring Energy Eraring Energy Project Manager Turbine Upgrade Project Turbine Asset Project Manager E&I Technician Operator Projects Engineer Operations Team Leader Environment Secretarial Support

HAZOP Study Report Of The Turbine Hydraulic Power Unit, Boiler Upgrade And Low Nox Burners As Part Of The Eraring Energy Power Station Upgrade Project

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1.1

INTRODUCTION
BACKGROUND

The Energy Directions Green Paper (Ref 1) prepared by the NSW Government identified that if the current trend of increased electricity demand continues, additional generation capacity or demand management would be required by 2010. Eraring Energy (EE), one of three State-Owned Corporations that manages a diverse set of electricity-generating assets located throughout NSW operates a coal-fired power station (at Eraring), known as Eraring Power Station (EPS). EE has put forward a proposal to undertake capacity increase and performance improvements to the existing EPS to increase the capacity of each of the four 660 MW generating units (which are capable of generating at an equivalent rating of around 700 MW) to enable the units to operate up to a maximum continuous rating of 750 MW. EE has obtained Project Approval, subject to a number of Consent Conditions, for the capacity increase project under section 75J of the EP&A Act in accordance with the provisions of Part 3A of the EP&A Act. The Minister for Planning is the approval authority for the application. One of these Consent Conditions requires a HAZOP Study to be undertaken for the proposed development, as follows: .....a Hazard and Operability Study (HAZOP) for the power station upgrade, chaired by an independent, qualified person or team. The independent person or team shall be approved by the DirectorGeneral. The Study shall be carried out in accordance with the Departments publication Hazardous Industry Planning Advisory Paper No. 8 HAZOP report. If the Proponent intends to defer the implementation of a recommendation, justification must be included.

1.2

AIM OF THIS REPORT

Eraring Energy has commissioned Planager Pty Ltd to lead a multidisciplinary team through the HAZOP Study of a number of sub-projects which form part of the EPS Upgrade Project. Planagers principal risk engineer, Karin Nilsson, has received approval from the Department of Planning to lead the HAZOP Study. The letter of approval for Karin Nilsson as HAZOP study leader is included in Appendix 2.

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The aim of the HAZOP study is to review a design of a technological system to identify hazards or significant obstacles to operability, which could arise, particularly through deviations from the design intent.

1.3

LOCATION OF EPS

EPSs site comprises approximately 1,200 hectares of land and is located in a natural dip on the western shore of Lake Macquarie. The site falls within the Lake Macquarie Local Government Area, near the township of Dora Creek, within the Morisset Planning District. The power station and associated infrastructure covers a footprint of approximately 150 hectares, with the remaining area including the CCP management facility, water canals, and ancillary power station facilities. The surrounds of the EPS consist largely of natural vegetated areas with development dedicated primarily to the extractive industries, such as coal mining. Some semi-rural areas exist to the south on the shores of Lake Macquarie.

1.4

PROJECT DESCRIPTION

The key objective of the project is to upgrade the infrastructure at EPS. By replacing existing aging components of plant and equipment within the EPS operating units, EE would be able to maintain operational capacity and the replacement/renewal program would enable improved efficiency of operations and the environmental and safety performance of EPS. The upgrade would allow the four existing 660 MW generating units to operate at a MCR of up to 750MW. This improved performance would be used to meet the increasing demands of the NEM, particularly during peak periods. Aged components of the Boiler and Turbine Generating Plant would be refurbished to achieve a MCR of 750 MW generated at a Power Factor of 0.9 at rated conditions (Generator 833 MVA rating). This would include: Steam Path Upgrade of high pressure, intermediate pressure and low pressure stages of the turbine; Upgrade of generator; Upgrade of generator transformer cooling system; Additional tubing inside boiler; Replacement of 28 boiler burners with low NOx burners; and Other miscellaneous work.

1.5

SCOPE OF HAZOP STUDY

EE has identified the following three operations which would benefit from a HAZOP Study:

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Boiler Upgrade Turbine Hydraulic Power Supply Low NOx Burners

The HAZOP study sessions were all carried out By Difference with the existing plant operation, i.e. the HAZOP focussed on the implication of the changes to plants and processes which result from the proposed changes to boilers, hydraulic unit and burners. As such, the HAZOP did not attempt to cover the whole of the Power Station operation and design. The scope of each HAZOP study is as follows: 1.5.1 Boiler Upgrade Included: The scope of the Boiler HAZOP includes the design and operation of the actual boilers. Excluded: The scope excludes the new (Low NOx Burners, see below), including the burner management, flame stability and wind box.

1.5.2 Turbine Hydraulic Power Supply Included: The scope includes the design and operation of pumps, fans, piping, valving, instrumentation etc. which form part of the hydraulic power unit. Excluded: The scope excludes the control system and the main oil pump and the auxiliary pump. The Emergency Trip Device is also outside the scope of this HAZOP. Further, outside the scope is the extractor relay dump valve operation, the Turbine protection and control module, the mechanical steam path upgrade. Note that at the time of the HAZOP the exact composition of the hydraulic oil was not known (it was believed to be some type of phosphate ester). The HAZOP team took into account that it could be potentially hazardous to people handling the material. As such the HAZOP of the turbine hydraulic power unit is regarded as a Preliminary HAZOP and further engineering investigation will be required (whether it be in the form of supplementary HAZOP studies or other risk management techniques). 1.5.3 Low NOx Burners Included: The scope of the Burner HAZOP included the new Low NO x Burners, including burner management, flame stability and wind box. Excluded: The control system was not part of the scope of this HAZOP.
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HAZOP Study Report Of The Turbine Hydraulic Power Unit, Boiler Upgrade And Low Nox Burners As Part Of The Eraring Energy Power Station Upgrade Project

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2.1

METHODOLOGY
INTRODUCTION

The HAZOP study is based on engineering line diagrams (P&ID's) and outline operating procedures. The consequences and deviations are identified, the existing safeguards are highlighted and, where necessary, appropriate corrective actions initiated. A HAZOP study is a form of design review which concentrates on how the plant will cope with abnormal conditions, rather than on how it will perform under normal conditions. The study comprises consideration of each process line and vessel, examining for each the possible causes and consequences of a wide range of process abnormalities. While some of the postulated abnormalities may be inapplicable for a particular process line, they are all probed with the objective of identifying any significant route to a process upset, operating problem or hazardous incident. It is, in effect, a very thorough but mainly qualitative approach. HAZOP is the method recommended for identifying hazards and problems which prevent efficient operation of a processing plant. It is a technique which provides opportunities for people to think creatively and examine all possible ways in which hazards or operating problems might arise. To reduce the chance that something is missed it is done in a systematic way - each pipeline and each type of hazard being considered in turn. The study is carried out by a team so that they can stimulate each other and build on each others ideas. The results of a HAZOP depend more upon the experience and attitudes of the participants and on the leadership style adopted, than on the procedures themselves. The participants were selected to provide the necessary experience, knowledge, skills and authority to approve the actions decided upon. The Study leader needs to be very experienced in HAZOP studies and Hazard Analysis techniques and capable of performing as an independent and unbiased leader. This person needs to be familiar with other related techniques and to know when other techniques would be beneficial compared to the HAZOP technique.

2.2

DETAILS OF THE HAZOP STUDY PROCEDURE

The HAZOP study was conducted according to ICI's traditional HAZOP methodology, corresponding to established engineering practices. The study of each step in the operation of the plant followed the pattern outlined below: A brief outline of the purpose of the step in the operation and of the lines involved with the operation is provided by one of the team members (usually by the designer). The lines are highlighted on the P&ID with dotted lines using a transparent coloured felt pen.
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HAZOP Study Report Of The Turbine Hydraulic Power Unit, Boiler Upgrade And Low Nox Burners As Part Of The Eraring Energy Power Station Upgrade Project

The purpose, design features, operating conditions, fittings, etc, are explained. Any general questions about the lines are then answered. The detailed "line by line" study commences at this point. The discussion leader takes the group through a series of guide words set out in a book (see Section 2.3). Each card has a guide word or prompt on it, such as "FLOW - HIGH", which identifies a deviation from normal operating conditions. This is used to prompt discussion of the possible effects of flow at an undesirably slow speed, and of the possible causes. If in the opinion of the meeting, the combination of the consequences and the likelihood of occurrence are sufficient to warrant action, then the combination is regarded as a "problem" and minuted as such. Potential incidents with severe consequences where the team judges that the risk management techniques already designed into the process are sufficient are also minuted in order to provide a record of the safeguards to be installed. Further, if a particular item was subject to discussions then it would be minuted to record the outcomes of these discussions. For major risk areas the need for action is assessed quantitatively. For less important risks the need for action can be based on experience and judgement. The person responsible for defining the corrective action is also nominated. It should always be remembered that the main aim of the meeting is to find problems needing solution, rather than determine actual solutions. If the group becomes tied down by trying to resolve a problem it is better to continue the discussion at a later date and proceed with the study. When each guide word requires no more consideration, the chairperson turns that card down revealing the next guide word. Discussion for each guide word is confined to the line marked, the vessels or other major equipment at each end and any equipment such as pumps or heat exchangers in between. Any changes agreed at the meeting are minuted, and where possible, marked on the P&I diagram or layout with red pen. When all guide words have been covered, the line is fully highlighted (instead of with a dotted line) to show that it has been covered, and the next line is chosen. When all the lines in a plant sub-section have been reviewed, additional guide words are used for review (overview) of the P&ID as a whole (see below).

2.3

HAZOP STUDY GUIDEWORDS

The guidewords applicable for continuous operations were used for the most of the designs under review. If the operation has critical sequencing conditions,

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such as for the Low NOx Burner project, then the continuous operation guidewords were complemented with batch guidewords as listed below. Line-By-Line Guidewords - Continuous Process High Level / High Flow Low Level / Low Flow Zero Flow / Empty Reverse Flow High Pressure - Venting, relief rate Low Pressure - Venting, relief rate High Temperature Low Temperature Impurities - gaseous, liquid, solid Change in concentration / Change in composition / Two phase flow / Reactions Testing - equipment / product Plant Items - operable / maintainable Instruments - sufficient for control / too many / correct location Toxicity Commissioning Start-up Shutdown (isolation, purging) Breakdown (including services failure) Effluent Fire and Explosion Safety Equipment Noise Materials of Construction Services required Electrical: area classification / isolation / earthing Quality and Consistency Output - reliability and bottlenecks Efficiency losses Simplicity Timing start too early/late; stop too early/late Flow High / Low Level High / Low Zero Flow / Empty Reverse Flow None Pressure High / Low Temperature High / Low
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Overview Guidewords

Line-By-Line Guidewords - Batch Process

HAZOP Study Report Of The Turbine Hydraulic Power Unit, Boiler Upgrade And Low Nox Burners As Part Of The Eraring Energy Power Station Upgrade Project

Density High / Low Viscosity High / Low Static Effects on Existing Equipment Concentration High / Low Contamination / Extra Phase Duration Delayed / Omitted Out of Sequence / Wrong Operation Not Complete Duplication Testing - equipment / product Plant Items - operable / maintainable Instruments - sufficient for control / too many / correct location Operator Health Environment Electrical Services Materials of Construction Non-routine Conditions - Start-up/ Shutdown / Maintenance / Cleaning / Commissioning Fire and Explosion Safety Equipment Quality and Consistency Output - reliability and bottlenecks Simplicity & Efficiency

Overview Guidewords

2.4

RISK RANKING TOOLS

The HAZOP Study was complemented with a formal risk ranking of each scenario using Eraring Energys risk ranking tool (Ref 2) presented in Appendix 3. This is as per Eraring Energys requirements for risk reviews of their projects.

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3.1

RESULTS AND RECOMMENDATIONS


PRESENTATION OF RISK RESULTS

Items were recorded on the HAZOP Study Record Sheets, which may be seen in Appendix 1. The 3.5 days HAZOP generated a total of 115 issues and recommendations. As per the methodology, entries were made on the record sheets as follows: Where a hazard or an operational problem was recognised as requiring further risk or operations controls; Where the potential consequences of an incident were severe even though the management of the risk considered acceptable. Where a particular item was discussed in detail during the study and hence required minuting to record the final outcome of these discussions.

HAZOPs are focussed on the engineering design of a particular plant or equipment. Hence, trip, slip and fall type incidents were not recorded nor were they discussed. These are better discussed in a Job Safety Assessment (or similar) type forum. The table in Appendix 1 shows the following columns: Risk Number, Guideword, Causes, Consequences Controls in place (a listing of the controls currently in place and approved as part of the present project), Current risk rating (rating of the risk with the controls which are currently in place or approved), Mitigating actions (further risk reduction recommendations aiming to reduce the risk to ALARP1 levels), Residual risk rating (the risk rating of the scenario with the recommended mitigating actions (above) in place,

Below is provided a listing of Levels 4 and 4 risk scenarios as identified and evaluated for the existing design. The resultant risk level once the recommendations arising out of the HAZOP Study have been implemented is also discussed for each scenario. The table in Section 3.5 below presents the

As Low As Reasonably Practicable


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risk profile of the systems under study assuming all recommendations have been implemented successfully.

3.2

RISK LEVELS OF THE BOILERS DESIGN

Below are listed the risk scenarios for each Risk Level (as per Eraring Risk definition) for the Boiler Design. These risk levels are as per current design without the additional risk reduction recommendations arising from the HAZOP implemented. 3.2.1 Level 4 Risks Boilers A. Risk of increased copper transportation (Scenario 5) Increased copper transportation has largely got a financial effect to EE. Copper would eventually carry-over through to turbine blades, reducing the efficiency of the turbine operation and hence output capacity. It may cause flow restrictions in superheater tubes and lead to a decreased life on low pressure heaters. The copper transportation issue will require a change in the manner in which maintenance is carried out on the superheaters and turbine rotors. Current controls include ongoing routine copper transportation survey; a Strategy Review which is being conducted on the merits of chemically cleaning the superheaters versus foam clean of turbine; a review of the procedures for boiler tube repairs have been reviewed; and new boiler chemical controls being installed to reduce copper transportation from LP heaters. Recommended additional controls are as follows: Option a: Successful chemical clean carried out on super heaters which will be carried out there-after as required need to review sliding pressure operation. This would reduce the consequences of this event resulting in reducing the overall risk level to a Level 3 risk. Option b: Replacement of LP heaters to allow oxygenated treatment of the boiler feed water. This would reduce the risk level to 1. NB: Eraring Energy has engaged a contractor to complete superheater tube cleaning commencing with unit four in November 2009. B. Insufficient power supplies or access for operation during construction (Scenarios 51 and 52) Insufficient power supplies for construction purposes and insufficient access for operations such as cranage due to other works (e.g. bottom ash hopper crushing plant and boiler upgrade crane location) would lead to delays in meeting program. The likelihood of such delays is seen as Very High leading to a Level 4 risk.

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It is recommended to place these risk scenarios on the Electrical Project Teams (#51) and Site Operations Managers (#51 and #52) agenda. This would reduce the risk to a Level 1 and Level 2 for scenarios 51 and 52 respectively. 3.2.2 Level 3 Risks Boilers A. Flow accelerated corrosion due to increase in normal operational flow (Scenario 1) Flow accelerated corrosion (FAC) is a temperature dependent corrosion mechanism normally occurring after a bend or in a straight pipe after a flow disturbance e.g. thermocouple probe, orifice plate etc. It may lead to pipe failure and loss of containment of high pressure water, injury from burns, possible fatalities. Existing controls are confirmation of adequate thickness of piping etc. (thickness survey already conducted); planned thickness surveys 4 years after start up and the fact that there is no change in geometry as a result of the project. Further recommendations are to determine high risk areas in terms of FAC and to perform thickness survey at targeted areas at first Combined Maintenance Outage Program (CMOP2) outage on units 4 and 2 and correlate to the duration above the original design flow. It is also recommended to record the extent of flow above the original design (for use in thickness survey mentioned above) and to confirm that FAC study by contractor has been completed and is valid for current design. Implementation of these recommendations would reduce the likelihood from a Moderate to a Low. It would however not reduce the overall risk rating, which remains a Level 3 risk due to the relatively High consequence rating. B. Failure of new pressure parts (Scenarios 7, 15, 19, 26, 50) Failure of new pressure parts for a number of reasons may lead to pipe failure and loss of containment of high pressure steam / water, injury from burns, and possible fatalities. Current and approved controls include the fact that the design and construction will adhere to Australian Standards including inspection; 100% radiography on all site tube welds; all other site welds to be NDT in compliance with Australian Standards; testing, including Non Destructive Testing (NDT); Asset Strategy defined field test for creep life of welds. Provided that these controls are successfully implemented and maintained the team concluded that the risk of these scenarios are As Low As Reasonably

A term generally used for planned generating unit maintenance and often associated with the phrase CMOP outage.
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Practicable (ALARP) and no further risk control measures were identified. The risk scenarios remain however at Level 3 risk due to the relatively High consequence should they occur even though the likelihood is considered as low as reasonably practicable. C. Increased maximum flow exceeds superheater safety valves (Scenario 14) maximum capacity of

An increase in the maximum flow may exceed the maximum relieving capacity of superheater safety valves. This would result in over pressurisation of the superheater leading to pipe failure and loss of containment of high pressure water, injury from burns, possible fatalities. Current controls include the review carried out by contractors in this regards which provides advice on the safe operation of safety valves. Recommendations are to establish actual flows for overload and revise plant control limits if necessary and to include (in the amended plant operating manuals) the established plant limitation. This would have the effect of minimising the likelihood of this event. However, due to the relatively High consequence of the scenario the risk level remains 3. NB: Review of flow rates from boiler designer indicates that operation to 750 MW will be achievable with installed safety valves. It is not expected that safety valve replacement will be required however it will be assessed post upgrade. D. Increase of velocities (Scenario 36) Boiler operation at higher loads increases average flue gas velocity which increases grit erosion. This could lead to tube failures and reduced boiler tube life and would increase maintenance/costs. Current and approved controls include Combined Maintenance Outage Program (CMOP) inspections and shielding, as identified in surveys for current known high wear area; existing baffling along the wall sections; and acoustic detectors to minimise damage in the event of a failure. Further, tube wall thickness design takes into account exposure to erosion and new economiser panels have all bends enclosed out of gas flow. Further recommendations from the HAZOP are for the design process to evaluate the need for baffling, shielding and soot blower locations in primary superheater and Reheater backpasses; the review to include rear wall penetration and seal boxes as now in an area of historical high risk. Prior to warranty expiration (12 months) take unit out of service for grit erosion survey on new design items; cold air flow testing and smoke bombs to identify high velocity areas and record high flow areas for targeted inspection - adjust baffling or shielding as required; perform inspections on previously un exposed areas while elements are removed during upgrade; and modify the boiler strategy to reflect concerns and learnings from inspections.
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Provided these recommendations are implemented the risk level of this scenario is reduced to a Level 2. E. Higher gas temperatures in the backpass (superheater and Reheater passes) (Scenario 42) Higher flue gas temperatures after the air heater exit and attemperation point will cause fabric filter bag failures due to excessive shrinkage. This could lead to cell isolations and potential breach of the environmental licence if EPS load not reduced. The failure may require long time to implement repairs if a stock holding of replacement bags is not available due to long lead time (3-6 months) on bags. The risk exposure exists until 2015 when all PAN filter bags would have been replaced. Currently EPS has excellent bag life with 6 to 7 year bag replacement cycle. Current and approved safeguards are using experience with this potential risk (which exists also in the existing plant); the new attemperating air system which initiates at 125 deg C, a High Alarm at 135 deg C and a High High Alarm at 140 deg C - for load reduction. Boiler flue gas design brief is 135 deg C at air heater exit at 720 MW with a 32 degree ambient air temperature. Fabric filter bag supply contract requires 8 cells of bags on site Further recommendation are for documentation to be produced to implement an operating limit of 135 deg C to manage bag life, with a nominal operating target of less than 130 deg C; adjustment of operating limit down on subsequent units if rapid multi cell failures occur; evaluating the need of attemperating air spray system if operating need exists; stock holding costs versus risk to be assessed; and investigation of stock holding limits with contracted supplier. If the recommendation above are implemented the risk is reduced to a Level 2 (possibly to a Level 1 depending on the rigour of implementation). F. Poor Access To Bottom Bank Reheater Tubes (Scenario 46) Poor access to bottom bank Reheater tubes may mean that in the event of a tube failure the outage may need to be extended to gain access to carry out repairs. There are currently no controls for this scenario (apart from a trained workforce with adequate operating procedures and PPE). Recommendation is if for a review to achieve workable access for maintenance. Provided this is workable access is achieved adequately the risk of this scenario is reduced to a Level 2.

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G. Change in boiler components (Scenario 53) Change in boiler components would result in change in load distribution. Currently structural review is being undertaken by contractor which also includes earthquake and wind load code compliance. Further action is to ensure that action resulting from design study to reflect latest Australian Standards and Codes. This would result in a Level 1 risk scenario. H. Changes to existing job sheets for boiler start up and shut down (Scenario 56 and 57) Changes to existing job sheets for boiler start up and shut down leading to plant damage or injury. Current controls are that boiler project team work scope includes procedural review. A tight control of the completion of plant modification process would result in a Level 1 risk. 3.2.3 Level 2 and Level 1 Risks Boilers There are a number Level 2 and Level 1 risks that were identified. These are detailed in Appendix 1.

3.3

RISK LEVELS OF THE TURBINE HYDRAULIC POWER UNIT DESIGN

3.3.1 Level 4 Risks Hydraulic Power Unit There are not Level 4 risks identified. 3.3.2 Level 3 Risks Hydraulic Power Unit A. Removal of Pump MRP Removal of Pump MRP causes Safety issue with 11MPa. Current controls are primary isolation valve and the pressure gauge. Recommended further controls are to ensure positive isolation to allow stand-by pump removal and to ensure the main isolation valves can be locked out. Provided these recommendations are implemented the risk level for this scenario is reduced to a Level 2 risk. B. Impact on fluid trip drain from valves back to tank causes pinching Impact on fluid trip drain from valves back to tank causes pinching resulting in an inability to trip turbine. This may, in adverse operating conditions, cause a burst of drain pipe over 1.4MPa with injury potential to personnel from high pressure event.

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Current and approved controls are the appropriate layout of piping (very short pipe) and protection of pipe between structures. Further recommendations are to review the layout of drainpipe to rule out impact; consult with contractor as to implications of a blocked drain line on operation; and to ensure EE field surveillance officer approves pipe line layout with attention to mechanical damage and weld inspection. The target is to ensure that this scenario becomes incredible. 3.3.3 Level 2 and Level 1 Risks Hydraulic Power Unit There are a number Level 2 and Level 1 risks that were identified. These are detailed in Appendix 1.

3.4

RISK LEVELS OF THE LOW NOX BURNER DESIGN

3.4.1 Level 4 Risks Low NOx Burners There are not Level 4 risks identified. 3.4.2 Level 3 Risks Low NOx Burners A. Pressure controller has been disabled or the Atomising air pressure is high (Scenario 12) If the pressure controller has been disabled or the atomising air pressure is high while atomising air to the ignitor it is possible for the unit to fail to ignite causing an operational upset and loss of power generation. Note that this is not a safety concern. It is recommended to review air pressure requirements with designers and respond appropriately. This would reduce the risk of this scenario to a Level 2. B. Inability to remove oil gun and spark rod on D level (Scenario 13) New burner layout may result in an inability to remove oil gun and spark rod on D level. Provided the design change to relocate oil gun to allow removal this scenario is reduced to a Level 1 risk. 3.4.3 Level 2 and Level Low NOx Burners There are a number Level 2 and Level 1 risks that were identified. These are detailed in Appendix 1.

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3.5

RISK PROFILE

The risk profile of the part of the plant assessed, assuming that the risk reduction measures recommended during the HAZOP Studies are all implemented successfully, is as follows: Table 1 Levels of Risk With HAZOP Recommendations Implemented Risk Level Boilers Level 4 Level 3 No scenarios identified remain at Level 4 FAC due to increase in normal operational flow (scenario 1) Financial effect only: Risk of increased copper transportation (scenario 5). Reduced to a Level 1 based on feasibility study. Failure of new pressure parts (scenario 7, 15, 19, 26, 50) Increased maximum flow exceeds maximum capacity of superheater safety valves (Scenario 14). Reduced to a Level 1 based on commissioning data and plant control settings. Level 2 Level 1 Detailed in HAZOP Minute sheets in Appendix 1 Detailed in HAZOP Minute sheets in Appendix 1 Risk Scenario

Turbine Hydraulic Power Unit Level 4 Level 3 Level 2 Level 1 No scenarios identified remain at Level 4 No scenarios identified remain at Level 3 Detailed in HAZOP Minute sheets in Appendix 1 Detailed in HAZOP Minute sheets in Appendix 1

Low NOx Burners Level 4 Level 3 Level 2 Level 1 No scenarios identified remain at Level 4 No scenarios identified remain at Level 3 Detailed in HAZOP Minute sheets in Appendix 1 Detailed in HAZOP Minute sheets in Appendix 1

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CONCLUSION

The formal HAZOP review process for major project is part of EEs multilevel risk management strategy and represents a clear commitment by EE as to the management of risks for the business and for safety, health and environment. This type of process allows for input by a number of experienced and senior representatives from operations, design, maintenance, safety etc. at a defined number of stages throughout the life of the project, from early conception through to detailed design and to final operation. It provides an opportunity for a multidisciplinary team to formally review a proposal and to use their experience and corporate memory to improve this proposal and wherever possible avoid any repeat of errors or issues that may have occurred in the past. The team that took part in the HAZOP reviews which are presented in the present report participated freely and with a high degree of expertise. This is apparent from the results from these HAZOP Study reviews which provides for a solid understanding as to the risks associated with the projects.

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Appendix 1

HAZOP Minutes Burner HAZOP Turbine Hydraulic Power HAZOP Low NOx Burner HAZOP

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BOILER HAZOP

No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

1 General Line: Feedwater from economiser inlet through to drum and furnace. 2 High Flow FAC due to increase in normal operational flow. May lead to pipe failure and loss of containment of high pressure water, injury from burns, possible fatalities Thickness survey already conducted. Planned thickness survey 4 years after start up, No change in geometry 4 2 3

a. Determine high risk areas in terms of FAC. Perform Thickness survey at targeted areas at first CMOP outage on units 4 and 2 and correlate to duration above original design flow. b. Record the extent of flow above original design (for use in thickness survey mentioned in action 1a above) c. Confirm that FAC study by CW has been completed and is valid for current design. 4 1

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

High Flow

Inability of drum to effectively separate water from steam at higher flow rates of upgraded design.

High Flow

Increased maximum flow exceeds maximum capacity of drum safety valves.

If drum unable to effectively separate water form steam, the possibility of carryover of water to superheater. Deposition of chemicals and erosion of turbine blades Over pressurisation of drum may cause failure. May lead to pipe failure and loss of containment of high pressure water, injury from burns, possible fatalities.

Design

Perform carry over test at commissioning of unit 4 and if carryover found engineer out (i.e. replacement separators)

Design review carried out by Connell Wagner and the safety valves on the drum have been confirmed to be adequate. (10% margin above 750MW flow rate.) With this safeguard in place this scenario has effectively been eliminated.

No further action identified.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

High Pressure

Risk of increased copper transportation

Eventually carry-over of copper through to turbine blades. Copper affects the efficiency of the turbine and may cause blockage in superheater tubes. The copper transportation issue will also require a change in manner of which maintenance is carried out on superheaters. Decrease life on LP heaters.

Ongoing routine copper transportation survey. Strategy Review being conducted on merits of chemically cleaning the superheaters versus foam clean of turbine. Procedures for boiler tube repairs have been reviewed. New boiler chemical controls are being installed to reduce copper transportation from LP heaters. Improved start up and shut down procedures.

a. Successful chemical clean carried out on super heaters and turbine. Carry out routinely if cannot stop copper transportation. brevier sliding pressure characteristic.

c. Replacement of LP heaters to allow oxygenated treatment (this option is being considered).

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

Low Flow

Imbalance of flow between front and back pass economisers

Low Flow

Failure of new pressure parts

Low Temperature

Design will lower economiser duty by 35%

Impurities

Construction debris left in system.

Flow may be too low in front pass encroaching in steaming margin. May cause pipe damage and level stability issues in drum (so called drum swell). Mixing at Tpiece may be unstable. May lead to pipe failure and loss of containment of high pressure water, injury from burns, possible fatalities. Lowering of the feedwater temperature to the drum which leads to higher gas flows and increased risk of erosion. Blockages, tube starvation and failure. Financial effect. Impact on human Safety low.

Design review carried out. Regular operational inspections to confirm design review outcomes. Hazard warning through noise.

Install thermocouples on each outlet header of economisers.

Design and constructed to standards including inspection, testing and NDT. Parameters have been given to designers as part of design scope and outcomes have been reviewed and accepted by Eraring. Construction methodology including flush processes. Visual inspections, ITP's

No further action identified.

No further action identified.

No further action identified.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

10

Reaction

Cooler temperatures in economiser

Possible reduced effectiveness of chemical dosing regime (particularly at start up)

Tube samples at outages. Continuous chemical monitoring. Upgrade of Chemical Control Room (CCR) with respect to instrumentation. Training requirements

Issue to be reviewed by Chemical Team.

11

Operability

New operating parameters

12

Operability/ maintainability

13

Instrumentation

Obstruction to galleries from new economiser feed pipe to drum. inadequate information of plant condition

Potential mal operation impacting life and viability of equipment. Poor access around and into boiler

New performance data sheets to be compiled.

Ensure adequate access around boiler

No further action identified.

Failure to understand plant condition

Existing instrumentation will be a guide to requirements for new equipment.

Refer to action No.6 w.r.t. thermocouples

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Line: Steam from the Heat Recovery Area outlet header through the Superheaters to the Main Steam Outlet 14 High Flow Increased Over pressurisation Designer review 4 2 3 a. Establish actual flows at maximum flow of superheater may carried out by CW. commissioning for overload exceeds cause failure. May Relieving capacity and revise plant limits if maximum lead to pipe failure reduced from IHI necessary capacity of and loss of design of 155.6 to b. Plant limitation to be superheater containment of high 139.4 kg/s. Minimum included in amended plant safety valves. pressure water, Aust Standard code operating manuals. injury from burns, requirements (20% of possible fatalities. steam flow relieving) equates to max steam flow rate of 695kg/s, hence steady state c. Based on findings in (a) 750MW flow determine need to install conditions of 624kg/s larger size safety valves to within this margin. allow achievement of Original design additional overload above assessment allowed 633 kg/sec (being 22% of for discharging 25% of the revised CW relieving steam flow rate capacity). through superheaters and under this basis 622 kg/s is maximum steam flow under original IHI design or 557 kg/s under revised CW capacity.

Impact

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Impact

No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

15

Low Flow

Failure of new pressure parts

16

High Temperature

Higher steam temperatures resulting in more frequent use of spray water Insufficient capacity of spray water to control superheater steam temperatures. Accelerated creep life consumption of headers

May lead to pipe failure and loss of containment of high pressure water, injury from burns, possible fatalities. Potential for thermal fatigue failure of spray water system

Design and constructed to standards including inspection, testing and NDT. Original design and material selection. 12-yearly inspections of spray water systems.

No further action identified.

Increase frequency of inspections of spray water system (currently 12yearly).

17

High Temperature

Accelerated creep life usage. Material Failure.

18

High Temperature

Reduced life of headers

Design parameter reviewed and accepted by Eraring Energy. Metal temperature operational limits and alarms (except SSH). Software system to monitor header life (ODAS). Field testing replication of headers

No further action identified.

Update/improve ODAS

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

19

High Temperature

Reduced creep life of welds

20 21

High Temperature High Temperature

Burner replacement Increased primary superheater surface area

Pressure part weld failure. Loss of containment of steam internal of boiler, could be external to boiler. Burns. Higher or lower temperatures Higher steam temperature for stages 1,2 and 3 resulting in higher metal temperatures causing metallurgical failure. Salt leak tolerance reduced due to lack of polishing plant capacity. Load reduction, boiler damage

Asset Strategy defined field test for creep life of welds

No further action identified.

To be covered in burner HAZOP Design review has indicated that materials are suitable for duty

To be covered in burner HAZOP No further action identified.

22

Impurities

Increased flow rate increases demand on polishing plant, particularly during periods of salt leaks

Reduce load as operating procedure. Polishing plant capacity review is carried out by CW

a. Implement actions from CW review on polishing plant capacity. OR

1 b. Review the turbine condenser life strategy

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

Increased Blocked super heater Not an issue at current exfoliation of tubes or solid particle operating conditions. internal stable erosion of HP turbine oxide layer due to the increase flow rate and heat fluxes 24 Instrumentati Inadequate Failure to understand TBA on information of plant condition plant condition Line: Steam from superheater outlet valve through the Reheater to IP Turbine 25 High Flow Increased maximum flow exceeds maximum capacity of Reheater safety valves. Over pressurisation of Reheater may cause failure. See No. 1 above. Design review carried out and confirmed. Maximum Reheater flowrate of 646kg/s for existing safety valves. Hence superheater safety valves are the first high flow limitation with respect to boiler safety valves. Boiler turbine matching review completed with outcome for boiler designer to advise of Reheater DP

23

Impurities

Desk top review of superheater metallurgy and susceptibility to the phenomena

Review instrumentation when it becomes available from designers No further action identified.

High Flow

Increased design flow and additional surface area increases DP across the Reheater

Reduced IP turbine inlet pressure which may lead to reduced output

No further action identified.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Rating Raw Risk

Impact

Impact

26

Low Flow

Failure of new pressure parts

27

High Temperature

Increased surface area enabling Reheater to exceed design temperatures

May lead to pipe failure and loss of containment of high pressure water, injury from burns, possible fatalities. Metallurgical failure of tubing resulting in loss of generation and revenue. Reduced Creep life on hot Reheater header.

Design and constructed to standards including inspection, testing and NDT. Temperature control with back pass dampers. ODAS system for creep life monitoring. Field replications as per strategy. Note: Existing spray water is decommissioned Material review carried out by designers

No further action identified.

Implement alarms on hot reheat steam outlet temperature. Implement appropriate training.

28

High Temperature

Tube failure of hot Reheater elements due to achieving design temperatures

Tube failure unit out of service, loss of revenue

No further action identified.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

Line: Furnace Area/gas side - from Ash hopper throat to furnace rear wall screen tubes. 29 High Flow Increased firing Increased gas flow causing increased vibration/movement on superheater pendants leading to tube failure. Outage inspections/condition monitoring, acoustic detectors will limit the impact. 2 2 2 No further actions 2 2 2

30 31

High Flow High Pressure

32

Low Pressure

33

High Temperature

No erosion issues identified Upgrade not affecting existing Upgrade not affecting existing Refer to Low NOx Burner HAZOP Slagging

No further actions No further actions

No further actions

No further actions

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) CMOP inspection for gap between pendants and nose

Further Mitigating Actions Furnace flue gas temperature measurements to confirm design expectations. Consider metal temperature instrumentation on SSH if flue gas temperatures high. As per 6.

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

34

High Temperature

Increased time at higher metal temperatures on superheaters.

Increased rate of creep life consumption requiring early replacement.

35

High Temperature

Increased temperatures on superheaters leading to increased metal temperatures

Increased rate of creep life consumption requiring early replacement.

CMOP inspection for gap between pendants and nose

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

Line: Backpass (superheater and Reheater passes) 36 High Flow Overall average velocity increases with reduced bias from front to rear pass specifically higher flow in the superheater compared to previously. High flow causes grit erosion Tube failures, increased maintenance/costs, shorter life CMOP inspections and shielding as identified in surveys for current known high wear areas. Existing baffling along the wall sections. Acoustic detectors to minimise damage in the event of a failure. Tube wall thickness design takes into account exposure to erosion. New economiser panels have all bends enclosed out of gas flow. 3 3 3
a) Design process to consider baffling, shielding and soot blower locations in primary superheater and Reheater. b) Review to include rear wall penetration and seal boxes as now in an area of historical high risk. c) Prior to warranty expiration (12 months) take unit out of service for grit erosion survey on new design items. d) Cold air flow testing and smoke bombs to identify high velocity areas and record high flow areas for targeted inspection - adjust baffling or shielding as required. e) Perform inspections on previously un exposed areas while elements are removed during upgrade. f) Modify the boiler strategy to reflect concerns and learnings from inspections.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) CMOP inspections to confirm if problem has increased from current

Further Mitigating Actions Inspect at 12 month warranty survey

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

37

High Flow

38

Low Pressure

Overall average velocity increases with reduced bias from front to rear pass specifically higher flow in the superheater compared to previously. High flow causes grit erosion Higher DP across finned economiser.

Possible increased grit erosion on dampers, with increased maintenance costs damper failure loss of temperature control

39

Low Pressure

Higher DP across finned economiser.

ID fan capacity margin is reduced which may lead to forced load limitation particularly in summer. More soot blowing to control dust build up in finn tubes, potentially causing higher rates of soot blower steam erosion on tubes leading to tube failure.

Soot Blowing

Review ID fan cut back set point with regards to the risk of duct implosion limits.

Shield soot blower steam impact areas.

No further actions

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) CMOP inspections

Further Mitigating Actions Review material selection

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

40

High Temperature

Higher gas temperatures.

41

High Temperature

Higher gas temperatures.

Affects uncooled metal on backpass including baffles, soot blower openings and nose sealing causing metallurgical degradation including plastic deformation and exfoliation leading to early replacement of items. Increased soot blowing to prevent air heater seizing (365 C max).

Existing plant limits and alarms, soot blowing

No further actions

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Using PAN/PPS bags since 2008 to increase operating temperature range from 125 to 135. Attemperating air system initiates at 125 deg C. High Alarm at 135 deg C with High High alarm at 140 degree - for load reduction Doosan Design brief basis is 135 C at air heater exit at 720 MW with a 32 degree ambient air temperature. Fabric filter bag supply contract requires 8 cells of bags on site

Further Mitigating Actions a) Documentation to be produced to implement an operating limit of 135 C to manage bag life, with a nominal operating target of less than 130 deg C.. b) Adjust operating limit down on subsequent units if rapid multi cell failures occur. c) Consideration of attemperating air spray system if operating need exists. d) Stock holding costs versus risk to be assessed. e) Investigate stock holding limits with contracted supplier.

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

42

High Temperature

Higher gas temperatures.

Fabric filter bag failures due to excessive shrinkage leading to cell isolations and potential environmental licence accidence if load not reduced. Long time to implement repairs due to long lead time (3-6 months) on bags. Risk exposure exists until 2015 when all PAN filter bags would have been replaced. Currently Eraring has excellent bag life with 6 to 7 year bag replacement cycle.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Has not been an issue at Eraring. Existing temperature Ok hence model accuracy at low load may be less precise than the design brief control range of 500MW +.

Further Mitigating Actions Additional baskets in air heater if required. If identified as an operational issue bid unit higher.

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

43

Low Temperature

Actual low load operation

44

Low Temperature

Actual low load operation

45

Impurities

Excessive tube fouling due to improper soot blower locations

Modelling indicates insufficient heat available for hot primary air at 300MW load resulting in mill outlet temperature drop of 10 deg C to 70 deg C during winter at 300MW - poor burner performance. Refer to Low NOx Burner HAZOP. Air heater cold end acid attack and plugging due to dew point resulting in additional maintenance outages and reduced life of air heater baskets. High boiler back end temperatures leading to issues above for high temperature.

Boiler modelling study indicates acceptable minimum temperature. SAH bypass allows regulation in winter at low load.

No further actions

Review of boiler design with regard to soot blower locations. Performance guarantee statement in boiler contract.

a) Review operational performance. b) Use contract to pursue performance short falls.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) None

Further Mitigating Actions Currently being discussed in design review to achieve workable access for maintenance Currently being discussed in design review to achieve workable access for maintenance Review alarm limits after initial operation or during commissioning.

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

46

Plant Items

Poor access to bottom bank Reheater tubes

47

Plant Items

Poor access to economiser feed main and Reheater inlet pipework Changed conditions

48

Instruments

In the event of a tube failure the outage may need to be extended to gain access to carry out repairs Difficult access for operators and maintainers leading to possible injuries or extensions of outage periods. Primary superheater temperatures hotter due to larger surface area meaning redefinition of plant limits.

None

None

Line: Overview 49 Materials for construction Poor quality or incorrect materials due to manufacture or transportation Site weld failing Tube failure or shortened life QA system, warranty, third party inspector and inspections. Experienced boiler manufacturer.
100% radiography on all site tube welds, all other site welds to be NDT in compliance with Australian standards.

No further actions

50

Construction

Tube failure and injury

No further actions

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) None

Further Mitigating Actions Place on Electrical project teams and Site Operations Managers agenda Place on Site Operations Managers agenda

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

51

Construction

52

Construction

53

Loads on structures

Insufficient power supplies for construction purposes Insufficient access for operations such as cranage due to other works eg bottom ash hopper crushing plant and boiler upgrade crane location Change in boiler components

Delays in meeting program

Delays in meeting program

None

Change in load distribution

54

Commissioning

New Plant

Operators not aware of issues or performance of new plant

Separate structural review being undertaken by Aurecon which also includes earthquake and wind load code compliance. Training of operators. Contractor to provide expected performance data sheets. Eraring Energy commissioning team to communicate change boiler performance.

Action resulting from design study to reflect latest Australian Standards and Codes

Confirm designer actively involved and present at commissioning.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Existing control will provide initial safe operation. Eraring Energy commissioning team to communicate change boiler performance.

Further Mitigating Actions Post commissioning optimisation tuning

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

55

Commissioning

New Plant

56

Start Up

New Plant

57

Shut down

New Plant

58

Breakdown

New Plant

59

Breakdown

New Plant

Superheater control system requires retuning to suit new plant to prevent header design material limits being exceeded and poor operational performance Changes to existing job sheets for boiler start up leading to plant damage or injury Changes to existing job sheets for boiler shut down leading to plant damage or injury Unidentified tube leaks causing extensive failure due to incorrect location of acoustic detectors. DNB leading to water wall failure

Boiler project team work scope includes procedural review

Completion of plant modification process

Boiler project team work scope includes procedural review

Completion of plant modification process

None

Locations being considered as part of design review

Modelling indicates DNB is not an issue at 750 MW. Money budgeted to purchase heat flux probes.

Install heat flux probes and alarm package to ICMS

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Boiler Upgrade Risk Review Stage 2 conducted 24th September 2008 TRIM doc09/15023 covers this issue. existing safeguards under OHS legislation and corporate policy Has been reviewed FD and ID confirmed with suitable margin. Current operating regime for emptying hoppers

Further Mitigating Actions No further actions

Likelihood

Likelihood

Rating Raw Risk

Impact

Impact

Rating Target

60

Safety

Crane operation and lifting

Injuries

61

Safety Equipment Output

Installation of new plant Higher firing rate

Injuries to personnel

No further actions

62

Increased air demand Capacity of hoppers and resultant overflow to air heaters increasing DP and causing potential load restrictions Insufficient milling capacity resulting in load restriction

63

Output

Higher firing rate

Review plant performance during and after commissioning. Review plant performance during and after commissioning.

64

Output

Higher firing rate

Modelling indicates marginal capacity if one mill unavailable for overload above 720 MW

Review plant performance during and after commissioning. Review classifier revised design if marginal.

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TURBINE HYDRAULIC POWER UNIT HAZOP

No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) To be determined

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

Location of HPU (cleaning aspects, fire from nearby facilities/equip ment, potential energy impact from items dropping from above, welding etc. etc.) Line: Fluid Actuator Supply (FAS) 2 High Pump fails to Pressure cut out

General

Security and integrity of operations

Location of HPU to be reviewed against security and integrity (cleaning aspects, fire from nearby facilities/equipment, potential energy - impact from items dropping from above, welding etc. etc.) Compliance with the Fire Safety Report to be checked

Pump dead heading, Pipe failure, pump failure, Unit out of service. Loss of electricity generation. Financial impact.

Relief valve FV-3 back to tank; Pressure sensors (x3) on manifold.

a) Provide detection and alarm for high pressure situation on manifold. b) Provide Eraring tag names on contractor's drawings.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Permit to Work system

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

General

Work on actuators

Injury to personnel

a) Ensure lines are depressurised b) Ensure PPE is used when contact with hydraulic fluid is possible No further improvements identified.

Low pressure

Blocked inlet to pipe, or blocked strainer

Loss of pressure to unit, inability to open valves. Loss of electricity generation. Financial impact.

Low pressure

Stand-by pump set on manual

Loss of pressure to unit, inability to open valves. Loss of electricity generation. Financial impact.

Stand-by pump cutin on low pressure; trip on low pressure; system to close valves; pressure switch across strainer with alarm. Alarm entry trip on low pressure; system to close valves

Provide adequate logic to ensure stand-by pump is available to cut in automatically on low pressure.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Stainless Steel and welded pipework; Low level alarm and trip on tank.

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

Low pressure

Pipe broken due to mechanical damage or fatigue

Loss of containment of ester, oil would escape (small spray failure through to large loss); environmental damage; possibly operator injury from high pressure and from harmful properties; unit shutdown. Financial effect.

Low Pressure

Loss of pressure through failure of NRV on the out-of-service pump

Loss of pressure to unit; Inability to open valves. Loss of electricity generation. Financial impact.

Alarm trip on low pressure; System to close valves; Contractor to supply a maintenance regime in OP and Maint manuals
Pressure switches 280A and 280B; Pump start switches and running switches.

a) More detail on pipe selection (is it seamless?) b) Request MSDS for ester. c) Ensure layout of all pipework associated with the HPU prevents impact from moving machinery. d) Dangerous Goods and Hazardous substances assessment to be implemented in accordance with the Codes e) Provide identification on Stainless steel lines eg coloured labels with directional symbols. f) Site installation to comply with AS4861. g) Provide rate of change alarm on oil tank to indicate an unusual (unscheduled) loss of oil supply. No further action recommended

Low Pressure

Stand-by pump switched on but fails to operate.

Loss of pressure to unit, inability to open valves. Shut-down of Unit. Financial impact.

ICMS logic to prevent shut-down of running pump before confirmation of adequate running of stand-by pump

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Low level alarm, Contaminated water drain captures spill.

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

Low pressure

Low level in tank due to drain valve left open or hole in tank

Loss of oil to valves, unit shut-down. Loss of electricity generation. Financial impact.

10

Reverse Flow

Malfunction of servo leading to excessive flow to one server. High Temperature of oil piping due to failure of cooling system

11

High Temperature

12

Low Temperature

Low oil temperature after outage

Loss of system pressure possibly leading to trip on low pressure. Loss of electricity generation. Financial impact. Possible burns if system temperature increases above normal; Shorten service life of equipment; Possible degradation of oil and seals; System malfunction. Loss of electricity generation. Financial impact. Low flow, unpredictable operation.

Unknown

a) Ensure appropriate job sheeting, PRIs. b) Training and documentation to define criticality of system c) Containment of fluid required to prevent entry into contaminated drains Ask contractor if the failure is possible and what are the safeguards

Maximum temperature 49 degrees before automatic switch on of cooling system, High temperature alarm above 66 degrees.

No further improvements identified.

Low temperature protection on start; Ability to heat oil

a) Contractor to advise minimum oil temperature interlock before starting after outage. B) Job sheets for cold start flow chart.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Automatic and continuous polishing filter; Sealed system except for opening for dryer; Maintenance for regime as per contractor specifications; A number of trips and alarms for system malfunction (e.g. Low pressure trips). Routine Testing of Stand-by Plant

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

13

Impurities

Contamination during maintenance, construction Filters not maintained; Equipment failure. Hydroscopic nature of ester - water in oil

Valves stuck, high wear, unpredictable operation, possible shut-down. Loss of electricity generation. Financial impact.

a) Routine oil sampling. b) Determine spare parts requirements. c) Routine maintenance as per OEM recommendations. D) How long can unit continue operating without the continuous polishing filter? - Check with contractor.

14

Testing

15

Testing

Failure to maintain equipment redundancy failure of plant items. Failure of protective devices

Loss of redundancy. Shut-down. Loss of electricity generation. Financial impact.

a) Set up routine testing in accordance with contractor's recommendations.

Plant damage or shut-downs. Loss of electricity generation. Financial impact. Failed ability to troubleshoot. Restricted access unless safety rail.

16

Operability Maintenability

Visibility of instrumentatio n

Routine Testing of protection devices. Fault tolerances. Redundancies for critical items. n/a

a) Set up routine testing in accordance with contractor's recommendations. B) Routine calibrations of instrumentation. a) Ensure all instrumentation can be easily read from ground level.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) n/a

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

17

Operability Maintenability

18

Instruments

Filters and other items requiring access for maintenance. No secondary isolation provided on pressure gauges PI280A, B, C

Unable to easily access filters while complying to OHS guidelines. Inability to isolate pressure gauge for removal in case of failure of primary isolation valve. Risk of injury during the removal of blanking plug. Injury to personnel Safety issue with high pressure (11 Map)

a) Review design to optimise ease of access for items that require maintenance eg filters

Primary isolation valve

a) Consult with Eraring to provide additional isolation and venting for instrument testing. b) the design is to be reviewed once the equipment has arrived on site

19

Operability Maintenance

Removal of Pump MRP

Primary isolation valve. Pressure gauge. (Non-return valve)

A) Ensure positive isolation to allow stand-by pump removal. (As per Eraring Energy requirements- EPS to mark drawings) B) Ensure main isolation valves can be locked out.

Line: two parallel FAS supply from tank - BY DIFFERENCE WITH ABOVE HAZOP OF FAS No additional scenarios identified Line: fluid emergency trip supply from tank through ETD towards valves (Hasp ETD as graybox) - BY DIFFERENCE WITH ABOVE HAZOP OF FAS No additional scenarios identified

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

Line: fluid trip drain from valves back to tank 20 High pressure Impact on line causes pinching Inability to trip turbine. Burst of drain pipe. Injury to personnel Appropriate layout of piping (very short pipe). Protection of pipe between structures. 4 1 3 A) Review layout of drainpipe to rule out impact. B) Consult with contractor as to implications of a blocked drain line on operation. C) Ensure EE field surveillance officer approves pipe line layout with attention to mechanical damage and weld inspection D)EE emergency procedures to be implemented to contain hydraulic fluid A) Review layout of drainpipe to rule out impact. B) Consult with contractor as to implications of a blocked drain line on operation. C) Ensure EE field surveillance officer approves pipe line layout with attention to mechanical damage and weld inspection. D)EE emergency procedures to be implemented to contain hydraulic fluid E) Review material selection of drain line to handle full system pressure in the event of a blockage (current design is 1.4 MPa versus supply pipe all pipework which is 11MPa) 3 1 2

Line: fluid drain - BY DIFFERENCE WITH ABOVE HAZOP OF FAS 21 High Impact on line Inability to position Appropriate layout pressure causes valve. Burst of drain of piping. Self pinching pipe. Injury to draining. personnel

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved)

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Line: Oil circulation loop through transfer and filtering pump, conditioning filter and polishing filter. 22 High Blocked filter Thermal overload on Pressure relief 1 2 1 Refer action number 13d) regarding pressure transfer pump motor valve, discharges how long unit can operate without into tank. Routine polishing system. filter maintenance. Local pressure gauges 23 Low pressure Mal-operation Potentially drain the Protection devices. 2 2 2 a) Proper job sheeting of valves or tank and trip unit on Drain directed to b) Training valve leak eg low oil tank level contaminated water c) Ensure ICMS logic trips transfer drain valve and/or low oil system. pump on tank low level and tank high FV-79 or pressure. Loss of high. sample valve containment, FV-75 or valve environmental Also refer to action 6g) regarding FV-78 or FVpollution. alarming on rate of change. 80 24 Low flow Pump failure Failure to polish. . Operator rounds 2 1 1 a) Refer action regarding how long Loss of electricity unit can operate without polishing generation. Financial system impact. b) Set-up operator routine to inspect oil system operations. 25 Impurities Filters in Functional spec a) Specifications calls for filters in series rather refers to filters in parallel. Drawing shows filters in than parallel parallel series - Contractor to clarify.

Impact

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Condition monitoring group exists on site

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

26

Testing

Failure to test oil in tank

27

28

Operable and maintainable Operable and maintainable

Access to conditioning filter Poor maintenance of oil conditioning system

29

Electrical

Location of emergency stop

Blockages and oil degradation. Maintenance problems leading to needing to overhaul all servos. Loss of electricity generation. Financial impact. Inability to maintain filters. Injury risk from fall from heights. Safety and operability. Possibility of draining oil out of tank. Environmental pollution. Loss of electricity generation. Financial impact. Unable to operate and stop HPU locally

a) Communication required with condition monitoring group b) Query whether phosphate ester is subject to organic growth

Work from heights procedure. PTW. Isolation valves exist. Drain directed to contaminated water system where it is contained.

No further action required

a) Adequate PRIs b) Lockable isolation valves and switches to conform with EE standards.

Not yet defined

a) Determine EE requirements and advise contractor with respect to location of start and stop buttons.

1 ta rg et 1

1 targ et

Line: Oil addition from drum through transfer and filtering pump, conditioning filter and polishing filter (BY DIFFERENCE) 30 Reverse flow FV -70 open during drum transfer or leaky FV-70 Reverse flow of oil back to drum unloading area. Environmental pollution. Operator vigilance. Contain spill 2 1 1 a) Additional check valve down stream of FV-78 b) Hydraulic fluid containment required 2 1

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) Labelling of drums.

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

31

Impurities

Contaminated oil, wrong oil, dirty hose

32

Operability and Maintainability

Leakage of oil from tank valving, field devices, drums, servos

Overwhelmed filter, stop polishing unit, degradation of fluid, total hydraulic oil system shut-down, damage to hydraulic components. Loss of electricity generation. Financial impact. Slippery surface, environmental pollution, loss of oil requiring more topups, hazardous substance (?) High oil temperature. Degradation of oil. Increase in oil pressure. Loss of electricity generation. Financial impact. Leads to excessive cooling

a) Filling and draining procedures required. b) Quality control of oil supply.

Housekeeping

a) Oil containment mitigation methods to be investigated. b) Implement emergency response procedures

1 ta rg et

1 targ et

Line: Cooling and heating systems 33 Low Flow Blocked Hydraulic fluid cooler Pressure relief valve FV-34. High temperature alarm. Duty stand-by cooler. Automatic shutdown of heating and cooling pump. Temperature transmitter. 2 1 1 a) Fix up drawing referring to TS2808 (temperature switch no longer there) 2 1 1

34

Reverse flow

Failure of the solenoid

a) Ensure manual override of solenoid valve.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) High temperature alarm. Duty standby cooler.

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

35

Reverse flow

Solenoid valve stuck in energised position Failure of flexible connection Pump failure Failure of cooling fan

36

Low pressure

37 38

Low pressure High temperature

Overheating leading to degradation of oil. Loss of electricity generation. Financial impact. Oil spill, trip on low pressure or on low tank level. Inability to cool or heat Overheating leading to degradation of oil. Loss of electricity generation. Financial impact. Commissioning program and ITP required to ensure safe and smooth commissioning Damage to plant. Personnel hazard

No action. Refer to action regarding how long the Unit can run without the polishing. a) Routine inspections and replacements. Refer to action rate of change 6g). a) Provide pump failure alarm (general for all pumps) a) Routine test operation of stand-by system. B) Suggest routine switchover of duty-stand-by systems.

Trips.

Duty stand-by. Temperature alarm. Duty stand-by cooler. Temperature alarm.

2 1

1 2

1 1

2 1

1 1

1 1

Overview 39 Commissioni ng

Commissionin g program and ITP

a) Contractors to supply commissioning program and ITP for EE approval.

40

Start-up and shut-down

Start up after outage and start-up of new unfamiliar plant. Routine Shutdown

Contractors responsible for commissioning and handover. Plan is 50% of operators will be trained prior to first start-up. Plant modification checklist completed.

Job sheets to be completed by the first start-up.

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No

Guide Word

Causes

Consequences

Safeguards (Existing and Approved) -

Further Mitigating Actions


Rating Raw Risk Impact

Likelihood

Likelihood

Rating Raw Risk

Impact

41

Commissioning

Construction, commissioning and handover of new plant items. Power failure

Procedures required. EE required to carry out checks.

a) EE to review procedures for construction, commissioning and handover of new plant items. B) EE to carry out 100% interlock and protection testing a) EE and contractor to finalise electrical schematics to ensure redundancy and fault tolerance No further improvements identified. 2 Enquire about CHAZOP or other review of control logic.

42

Breakdown

Plant failure, possible unit shutdown Blockages and oil degradation. Logic error

Redundant power supply to HPU. Routine replacement -

43 44

Breakdown Breakdown

Vents ICMS failure

1 ta rg et 1 ta rg et

1 targ et 1 targ et

45

Fire and explosion

46

Extreme limitation

Combustible nature of Esther unknown (it is not a flammable material) a) Flexible hoses b) Servos contamination of fluid

Fire damage.

Contractor to supply details of hydraulic fluid

Scenarios identified above. No new scenarios identified here.

Scenarios identified above. No new scenarios identified here.

No further improvements identified.

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LOW NOX BOILER HAZOP

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Appendix 2

Approval for HAZOP Leader

Report of the Preliminary HAZOP Study for the Hydrogen Circuit at the New Hydrogen Plant at Eraring Energy, Eraring, NSW

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Phone: Fax: Email:

02 9228 6108 02 9228 6433


derek.mullinsa@planning.nsw.gov.au

Ms Karin Nilsson Planager Pty Ltd PO Box 248 Berowra Heights NSW 2082 4 May 2009 Dear Ms Nilsson Subject: Eraring Eneregy Power Station Upgrade HAZOP I refer to your letter, dated 27 April 2009, seeking approval for you to lead the HAZOP for the above project. On the basis of the information previously supplied on your qualifications and experience, you are approved to conduct the HAZOP. You should note that the approval is specific to the current project and that separate approvals will need to be sought for any future HAZOPs. If you have any further queries, please dont hesitate to contact me. Yours sincerely

Our ref: Your ref: File: Eraring power station upgrade HAZOP Chair.doc

Dr Derek Mullins Director, Major Hazards

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Appendix 3

Eraring Energy Risk Tool

Report of the Preliminary HAZOP Study for the Hydrogen Circuit at the New Hydrogen Plant at Eraring Energy, Eraring, NSW

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Overall Risk Rating CONSEQUENCES

LIKELIHOOD

Very High 4 High 3 Medium 2 Low 1

Low 1 3 2 1 1

Medium 2 3 2 2 1

High 3 4 3 2 2

Very High 4 4 4 3 3

Table 2 Risk Rating Classification


Risk Rating of 3 Risk Rating of 4 Risks rated 3 and 4 are defined as material and are summarised in the Project Management Plan, Form PMF2-1 for presented to the Sponsor and the Steering Committee. Risks rated 1 and 2 should be identified and included in the Risk Register worksheet of the Risk Management Plan, Form PMF2-4 to allow appropriate monitoring.

Risk Rating of 1

Risk Rating of 2

Table 3 Likelihood and Frequency Rating


Low 1 Probability occurrence Likelihood occurrence of of 10% Remote Unlikely to occur Medium 2 30% Possible Could occur High 3 60% Probable Likely to occur Very High 4 90% Almost Certain Almost certain to occur

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Table 4 Consequence Rating


Corporate Category
Operating Profit

Risk

DRAFT Indicative project risks that fall under this corporate category Budget overruns Forecasted benefit shortages Contractor insolvency Inaccurate estimates Procurement delays Insurance claims

Low 1
Impacts operating profit between $0.5m - $2m

Medium 2
Impacts operating profit between $2m - $5m

High 3
Impacts operating profit in between $5m - $10m

Very High 4
Impacts operating profit in excess of $10m

Trading Margin

Gross

Generation Operations

Unscheduled outages Delays in plant completion

Impacts energy trading gross margin between 0.5% - 2.0% (between $2.4 and $9.5 million) of budgeted annual gross margin Minimal impact on achieving operational objectives Short term Minor loss of plant function with minor impact on production

Impacts energy trading gross margin between 2.0% - 5.0% (between $9.5 and $23.8 million) of budgeted annual gross margin Moderate impact on achieving operational objectives Generation capacity reduced by 1 unit for less than 7 days or MW/hr equivalent OR Loss of Kangaroo Valley Units for less than 7 days

Impacts energy trading gross margin between 5.0% - 10.0% (between $23.8 and $47.5 million) of budgeted Significant achieving objectives impact on operational

Impacts energy trading gross margin by more than 10% (greater than $47.5 million) of budgeted annual gross margin Detrimental impact on achieving operational objectives Generation capacity reduced for more than 14 days or MW/hr equivalent or the loss of 3 or more units simultaneously.

Generation capacity reduced by 1 unit for more than 7 days or MW/hr equivalent or loss of 2 or more units simultaneously. OR Loss of Kangaroo Valley Units for more than 7 days

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Corporate Category
IT Systems

Risk

DRAFT Indicative project risks that fall under this corporate category System outages Loss of data

Low 1
Short term loss of critical applications with minor business operational impact Short term loss of telecommunication services with little impact as alternative service capability is available Minimal complaints.

Medium 2
Loss of critical IT Systems having a business operational impact for < 1 day Loss of telecommunication services for <1 day having a minimal operational business impact. Several complaints. Local media coverage.

High 3
Loss of critical IT Systems having a business operational impact for > 1 day but < 2 days Loss of telecommunication services having a business operational impact for >1 day but <2 days. Multiple complaints State media coverage

Very High 4
Loss of critical IT Systems having a business operational impact for > 2 days Loss of telecommunication services having a business operational impact for >2 days. Multiple complaints serious

Telecommunications

Media

Readily respond to local forums

National media coverage Significant impact to relationship with Eraring Energy major stakeholders Significant impact to relationships with multiple Eraring Energy major stakeholders

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Corporate Category
Environment

Risk

DRAFT Indicative project risks that fall under this corporate category Spills Waste disposal Contractor practices Environmental breaches (e.g. oil/chemical/noise)

Low 1
Nuisance impact / Localised

Medium 2
Short term issue, reportable to DECC but no environmental impact. Minor compliance issue or improvement notice issued

High 3
Medium term/environmental impact issue, reportable to DECC. Possible response services emergency by external required

Very High 4
Long term/serious environmental incident, DECC involvement Emergency response required from external services Definite prosecution or fine > $100,000 WorkCover Prosecution (WC)

Safety

Risk of injuries Workcover claims

Minor injury first aid required / Medical treatment injury (MTI) No lost time

Loss Time Injury (LTI) < 7 days

Definite prosecution or fine < $100,000 WorkCover (WC) Notifiable Event LTI Incident > 7 days

Regulatory Legislative requirements

and

Changes legislative requirements

in

Minor breach not required to be reported to Regulator

Breach requiring noncompliance to be reported to Regulator Incident investigation Regulator Sanctions possible involving by

Prosecution Regulator

by

Sanctions (eg fines) imposed by Regulator

Serious injury or fatality or multiple injured persons. Prosecution by Regulator or regulators involving multiple persons Sanctions (eg fines) imposed by Regulator on multiple persons

(eg.)

fines

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REFERENCES

1 2

NSW Government, Energy Directions Green Paper, December 2004 J Gaillard, Project Management Risk Assessment Guidelines, Guideline PMF2-4a, Eraring Energy, 8 May 2009

HAZOP Study Report Of The Turbine Hydraulic Power Unit, Boiler Upgrade And Low Nox Burners As Part Of The Eraring Energy Power Station Upgrade Project

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c:\erapow\12-b177\HAZOP Report Upgrade Project Rev B.Doc Rev B : 14 July, 2009

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