34 industrial drive, ulverstone tas asphalt suppliers pty ltd · msds material safety data sheet...

ENVIRONMENTAL ASSESSMENT REPORT

Asphalt Plant

34 Industrial Drive, Ulverstone TAS Asphalt Suppliers Pty Ltd

Report and recommendations of the

Environment Division

Department of Environment, Parks, Heritage and the Arts

to the Board of the Environment Protection Authority

November 2008.

Environmental Assessment Report – Asphalt Suppliers Pty Ltd; Asphalt plant, Ulverstone.

I

Environmental Assessment Report

Proponent Asphalt Suppliers Pty Ltd.

Proposal Asphalt Plant.

Location 34 Industrial Drive, Ulverstone TAS 7315.

NELMS no. 7550.

DA number DEV.2008.15.

File 11 07 31.

Document Eeo/eas/p/AsphaltSuppliers_Asphalt/ar.

Assessment process milestones

30 October 2007 Notice of Intent submitted.

7 December 2007 DPEMP Guidelines issued. 6 August 2008 Permit application submitted to Council.

8 August 2008 Application received by Board.

16 August 2008 Start of public consultation period.

12 September 2008 End of public consultation period.


II

Acronyms

AQA Air Quality Assessment (Appendix C of the DEPMP).

Board Board of the Environment Protection Authority.

DEPHA Department of Environment, Parks, Heritage and the Arts.

Director Director, Environment Protection Authority.

Division Environment, DEPHA.

DHHS Department of Health and Human Services.

DPEMP Development Proposal and Environmental Management Plan.

DRP Decommissioning and Rehabilitation Plan.

EIA Environmental Impact Assessment.

EMPC Act Environmental Management and Pollution Control Act 1994.

EMPCS Environmental Management and Pollution Control System.

EPA Environment Protection Authority.

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth).

Air EPP Environmental Protection Policy (Air Quality) 2004.

FPA Forest Practices Authority.

FPP Forest Practices Plan.

LUPA Act Land Use Planning and Approvals Act 1993.

MSDS Material Safety Data Sheet

NIA Noise Impact Assessment (Appendix D of the DPEMP).

OU Odour Unit

RMPS Resource Management and Planning System.

SD Sustainable Development.

The Land The subject site as shown at Figure 1.

tpa Tonnes per annum.

TSP Total Suspended Particle.

PAH Polycyclic Aromatic Hydrocarbon.

PM10 Particulate Matter less than 10μm.

VOC Volatile Organic Compound.


III

Report summary This report contains an environmental assessment and recommendations to the Board of the Environment Protection Authority (the Board) in relation to Asphalt Suppliers Pty Ltd’s proposed Asphalt Plant.

The proposal involves the construction and operation of a pre-mix bitumen plant and associated infrastructure located at 34 Industrial Drive, Ulverstone in the Central Coast region of Tasmania.

This report has been prepared by the Environment Division (the Division) of the Department of Environment, Parks, Heritage and the Arts (DEPHA) based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP). The advice of relevant Government Agencies and the public has also been sought and considered as part of this assessment.

Background to the proposal and details of the assessment process are presented in Section 1 of this report. Section 2 describes the context of this assessment. Details of the proposal are contained in Section 3. Section 4 reviews the need for the proposal and considers the site and design alternatives. Section 5 summarises the public and Agency consultation process and the key issues raised in that process. The detailed evaluation of key issues is contained in Section 6. Section 7 identifies other environmental issues and the report conclusions are contained in Section 8.

Appendix 1 contains a tabular evaluation of the other environmental issues referred to in Section 7. Appendix 2 contains additional acoustic data referred to in section 6. Appendix 3 contains a summary of issues raised in the consultation process. Appendix 4 contains recommended environmental permit conditions for the proposal. Attachment 2 of the recommended permit conditions contains the table of commitments from the DPEMP.


IV

Recommendations It is recommended that the Board:

1. Consider the Division’s evaluation of environmental issues associated with the proposal in Section 6 and Section 7 of this report.

2. Note that the evaluation has concluded that the proposal is capable of being managed in an environmentally acceptable manner such that it is unlikely that the Resource Management and Planning System of Tasmania (RMPS) and Environmental Management and Pollution Control System (EMPCS) objectives would be compromised, provided that the recommendations made in this report are satisfactorily implemented. These recommendations include the implementation of the commitments made by the proponent in the DPEMP.

3. Approve the proposal subject to the conditions attached to this report.

4. In accordance with s.25(5)(a)(i) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), notify Central Coast Council that the conditions and restrictions detailed in Appendix 4 (recommended permit conditions) must be contained in a permit granted by the planning authority under the Land Use Planning and Approvals Act 1993 (LUPA Act) in respect of the proposal, if a permit is to be granted.

5. In accordance with s.25(5)(a)(ii) of the EMPC Act, provide Council with a copy of this report to outline the reasons for the conditions and restrictions.


VI

Table of Contents

1. Approvals process ................................................................................ 1

2. SD objectives and EIA principles .......................................................... 1

3. The proposal ......................................................................................... 2 4. Need for proposal and alternatives ....................................................... 8

5. Public and agency consultation ............................................................ 9 6. Evaluation of key issues ..................................................................... 10 6.1 Atmospheric emissions .................................................................................................. 10

6.2 Noise emissions ............................................................................................................. 16

6.3 Water Quality and Erosion ............................................................................................. 20

7. Other environmental issues ................................................................ 22

8. Conclusions ........................................................................................ 23 9. References ......................................................................................... 23 10. Summary of appendices ..................................................................... 24

Appendix 1: Assessment of other environmental issues .......................................................... 25

Appendix 2: Additional Acoustic Data ....................................................................................... 32

Appendix 3: Summary of issues raised by public and agency submissions ............................. 38

Appendix 4: Proposed permit conditions .................................................................................. 43

Table 1: Summary of key proposal characteristics ......................................................................... 2

Figure 1: Proposed location (Figure 1 of the DPEMP) ..................................................................... 6

Figure 2: Process overview (Figure 4 of the DPEMP) ..................................................................... 6

Figure 3: Site plan (Figure 2 of the DPEMP) 7

Table 2: Typical hot mix asphalt plant emission control technologies .......................................... 13

Figure 4: Odour modelling showing the effects of non-continuous emissions (Figure 8 of the DPEMP) ........................................................................................................................... 15

Figure 5: Proposed noise emission limits compared to current noise levels at Westella ................ 19


1

1. Approvals process An application for a permit under the LUPA Act in relation to the proposal was submitted to Central Coast Council on 6 August 2008.

The proposal is defined as a ‘level 2 activity’ under Schedule 2 Subsection (7)(d) of the EMPC Act, being the operation of a pre-mix bitumen plant capable of producing more than 1 000 tonnes of material per year.

Section 25(1) of the EMPC Act required Council to refer the application to the Board for assessment under the Act. The application was received by the Board on 8 August 2008.

A DPEMP was submitted in support of the application. The DPEMP was prepared in accordance with guidelines jointly issued by the Board and Central Coast Council. The final guidelines were issued to the proponent on 7 December 2007.

Several drafts of the DPEMP were submitted to the Division for comment prior to its formal submission. A final DPEMP was submitted to Council with the permit application. The DPEMP was released for public inspection for a 28-day period commencing on 16 August 2008. Advertisements were placed in The Advocate and The Mercury. The DPEMP was displayed at the council offices in Ulverstone, the environment library, Hobart and on the Environment Protection Authority (EPA) web site. The DPEMP was also referred at this time to relevant government agencies for comment. Eight public submissions were received.

2. SD objectives and EIA principles The proposal must be considered by the Board in the context of the Sustainable Development (SD) objectives of the RMPS, and in the context of the objectives of the EMPCS established by the EMPC Act. The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to protect the environment of Tasmania, and to further the RMPS and EMPCS objectives.

The Board must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment (EIA) Principles defined in Section 74 of the EMPC Act.


2

3. The proposal The proposal is for the construction and operation of a fully computerised control and direct drive asphalt mixing plant and associated infrastructure at 34 Industrial Drive, Ulverstone (Figure 1). The plant will produce approximately twenty thousand tonnes of asphalt per annum and will supply asphalt to Harding’s Hotmix Pty Ltd as well as other users of the product.

Process The DPEMP summarises the batch mixing process as involving the following key steps (Figure 2):

Raw materials are delivered to the plant via road transport. Upon arrival to the site, aggregate and sand are delivered into raw material storage bays;

Aggregate is transported by front end loader from the storage bays to the cold bin;

Aggregate leaves the cold bin via conveyor belt to a rotary dryer and into the burner;

Hot aggregate leaves the burner via a hot elevator and is transferred to vibrating screens that sort aggregate into hot bins according to size;

The aggregate from the hot bins is then mixed to achieve a desired aggregate size distribution and weight;

Liquid bitumen is pumped from heated storage and added to the aggregate to achieve the desired asphalt mix;

Prior to loading asphalt, truck decks are sprayed with ‘Truck-slip’ to prevent asphalt adhesion; and

The final product of asphalt is transported off site by truck.

The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 3 of the DPEMP.

Table 1: Summary of key proposal characteristics

Characteristic Description/quantities

Activity description The construction and operation of a pre-mix bitumen plant with an annual production rate of approximately 20 000 tonnes per annum (tpa).

Location 34 Industrial Drive, Ulverstone.

Land Title reference: CT 146935/2.

Co-ordinates (GDA 94) 433150E, 5443408N.

Land zoning The subject land is zoned ‘Industrial’ under the Central Coast Planning Scheme 2005.

Asphalt plants are a discretionary use under the planning scheme.

Land tenure Private.

Site overview The site lies just north of the Bass Highway at the south eastern end of the Ulverstone industrial area and approximately 1.7 km east of Ulverstone town centre.

The site is situated on “older stabilised Aeolian sand of coastal plain”.

The topography of the site is relatively level, lying at an elevation of approximately 10 m above sea level (asl).

The site is currently vacant, cleared land with two small isolated communities of Melaleuca ericifolia swamp forest along the northern boundary.

The site is connected to existing council water, sewer and storm-water


3

Characteristic Description/quantities services. An electricity connection is also available to the subject site.

The subject site contains a number of drainage easements.

The site has a singular road frontage onto Industrial Drive.

There is a row of storage facility units along the sites eastern boundary. These will remain on the site.

Surrounding area overview

The Bass Highway runs parallel to the south of the subject site.

Land in a 250m radius to the west, north and east is zoned Industrial; The industries immediately surrounding the proposal site include a pyrethrum manufacturer, an agricultural machinery supplier and a bakery.

Westella bed and breakfast is located approximately 150m to the south-east of the site, on the other side of the Bass Highway in an area zoned Rural Resource. Land to the southwest is Low Density Residential.

The next nearest residential properties are located approximately 450m to the north-west of the proposed location of the site within the Closed Residential zone.

Approximately 400 metres to the north is the coastal Environmental Management Zone.

The area around Ulverstone is relatively flat, with the exception of some steeply incised river valleys. Approximately 700 metres south of the site is a scarp that rises steeply to 50 metres above sea level.

The Goat Island Conglomerate is the nearest geoconservation area and is located approximately 4 kilometres from the site.

Major equipment

Construction equipment on site is expected to include a dump truck, concrete mixer, grader, excavator and a crane.

The asphalt plant consists of the following key components: cold bin and belt feeder; horizontal belt conveyor; scalping screen; slant belt conveyor; dryer; dryer burner; turbo blower; blower control system; hot elevator; vibrating screen, hot bin; aggregate weighing; asphalt weighing; filler/optional dust weighing; mixer (twin shaft pugmill), asphalt spray pump; filler/dust supply system; asphalt tank, asphalt supply pump, asphalt piping; hot oil heating system; fuel supply system, control system; electric power supply system; compressed air supply system; primary dust collecting system (cyclone); secondary dust collecting system (bag filter).

Other infrastructure The site will be secured after hours by existing gates and fencing.

Concrete hard stand area for the Asphalt Plant, associated infrastructure.

Safety shower.

Materials storage tanks.

Open storage bins for aggregates and sands.

Small office and staff amenities.

The proposed development is not expected to require any upgrade of offsite features such as roads, power supply, water supply, sewer or stormwater systems.

Inputs

Water A minimal volume of water will be required for activities such as dampening down/dust suppression. Other water uses on site include general use, toilets and safety showers. This water will be sourced from council mains water supply.


4


Energy Fuel (diesel) for mobile equipment.

Natural gas for the dryer burner, and to heat the oil which will be circulated around the bitumen storage tanks.

Electricity for all conveyors, pumps and other equipment. The anticipated power requirement for the plant when fully operational is 237.1 Kilowatts.

There will be additional, minor, power requirement to run ancillaries such as computers and office/bathroom requirements.

Other raw materials Concrete for hardstand area.

There are minimal material requirements for the proposed construction period due to the pre-fabricated nature of the plant.

A production level of 20 000 tpa will consume a similar quantity of raw materials.

Sand will be sourced from Wynyard.

Other aggregate material will be sourced from local suppliers in Ulverstone.

Bitumen will be delivered to site up to twice weekly by a 25 tonne truck.

Wastes and Emissions

Liquid The asphalt mixing process has no waste water stream so liquid waste is limited to domestic water (including the safety shower) and stormwater.

Atmospheric Atmospheric emissions associated with the construction of the plant will principally be dust and vehicular emissions.

Operations will result in the production of a range of potential pollutants. These are identified in the DPEMP as odour, dust, total suspended particulates (TSP), particulate matter less than 10μm (PM10), volatile organic compounds (VOCs), asphalt fume (Total Organic Carbon), blue smoke, oxides of nitrogen, sulphur dioxide, carbon dioxide, carbon monoxide and Polycyclic Aromatic Hydrocarbons (PAHs).

Solid Waste materials and packaging will be generated during the construction period.

Operational waste produced is expected to be; small quantities of office and domestic waste, waste oils and material from the sumps, baghouse filter bags, and oily rags.

Noise Noise will be generated by all construction machinery.

The major operational noise sources are anticipated to be from the bag house filter. Other noise sources include vehicle movements and noise resulting from general materials handling.

Operating hours Proposed operating hours are:

Construction: 0700 to 1800 Monday to Friday.

0800 to 1300 Saturday.

Operation: 0600 to 1800 Monday to Friday.

0600 to 1600 Saturday.

No production will occur on Sundays or public holidays.

Project timetable Construction: will last approximately 6 weeks, site works required prior to delivery of the plant are: clearance of existing vegetation from the site; establishment of hard stand areas and concrete pad for plant; installation of site drainage network; establishment of roadways; and installation of open storage bins for aggregates and sands.


5


Once the site is prepared in this manner, the plant producers will ship the plant to the site in shipping containers and arrange for a crew to undertake installation and commissioning.

Commissioning: will last approximately 2 weeks. The commissioning process will be undertaken by the plant producers in conjunction with Asphalt Suppliers.

Life of Operation: expected to be more than 25 years.

Other key characteristics

The operational phase of the Asphalt Plant is anticipated to lead to a minor increase in trucking movements (from around 6 per day up to approximately 20) within the vicinity of the plant. The DPEMP states that these truck movements are not associated with additional trucks on the road in general, but rather a diversion of trucks from other locations.


6

Figure 1: Proposed location (Figure 1 of the DPEMP)

Figure 2: Process overview (Figure 4 of the DPEMP)


7

Figure 3: Site plan (Figure 2 of the DPEMP)


8

4. Need for proposal and alternatives Need for the Proposal The proposed asphalt plant will be the supplier of asphalt to Harding’s Hotmix Pty Ltd and other customers. Harding’s Hotmix currently source asphalt from external sources. The DPEMP states that this process can often result in delays in obtaining asphalt. It is anticipated that this delay will be eliminated by this proposal, leaving Harding’s Hotmix better equipped to meet demand for asphalt within the community and that this may lower the cost of supplying asphalt to the community.

Technological alternatives The proposed model of asphalt plant was considered by Asphalt Suppliers to be the most suitable of a range of potential providers due to price, size, ease of operation and degree of environmental management and protection.

An existing asphalt plant in Launceston is a similar model and information obtained by Asphalt Suppliers suggests it is a reliable and effective plant. In addition, it was considered that having two plants from the same manufacturer, in the region, would improve efficiency for maintenance and ongoing support.

As the proposed plant provides industry standard environmental controls, (discussed in Section 6 of this report) it was not considered necessary to undertake any further investigation of plant options.

Alternative Sites As the Industrial Drive site is located within an industrial zone and is immediately adjacent to Harding’s Hotmix, to whom Asphalt Suppliers is to be the sole supplier, the site is considered by the proponent to be the ideal location for the development. As such, no other sites were considered for this project.


9

5. Public and agency consultation A summary of the public representations and government agency/body submissions is contained in Appendix 3 of this report. Eight public representations were received. The main issues raised in the representations were:

• Odour;

• Dust; and

• Noise.

The DPEMP was referred to a number of government agencies/bodies with an interest in the proposal. Responses were received from the following:

Public and Environmental Health Service of the Department of Health and Human Services (DHHS).

Workplace Standards Tasmania of the Department of Justice.

The following Divisions/Areas of the DEPHA also provided submissions on the DPEMP:

• (Air Specialist) Environment Division;

• (Noise Specialist) Environment Division;

• Heritage Tasmania.

The proponent has also communicated with the Central Coast Council which, the DPEMP states, has expressed support for the proposal.


10

6. Evaluation of key issues The key environmental issues relevant to the proposal that were identified for detailed evaluation in this report were:

− Air emissions;

− Noise emissions; and

− Water quality and erosion.

These issues are discussed individually in the following Sections. The table of commitments from the DPEMP is included as Attachment 2 to Appendix 4 of this report.

6.1 Atmospheric emissions

Description

A project specific Air Quality Assessment (AQA) was included as Appendix C to the DPEMP. The AQA was summarised in the DPEMP and included modelling for both point and fugitive sources of emissions and predicted concentration levels for a range of pollutants. Potential pollutants identified in the DPEMP were odour, dust, total suspended particulates (TSP), particulate matter less than 10μm (PM10), volatile organic compounds (VOCs), asphalt fume (Total Organic Carbon), blue smoke, oxides of nitrogen (NOx), sulphur dioxide, carbon dioxide, carbon monoxide and polycyclic aromatic hydrocarbons (PAHs). These emissions have the potential to impact on the local industries and residences. The nearest industry is adjacent to the northern boundary of the site and the nearest residence, Westella house, is approximately 150 metres from the site.

The DPEMP concluded that:

• Atmospheric impacts from the construction of the plant, and associated vegetation removal, are expected to principally result from dust and vehicular emissions.

• The most significant point source of particulate matter and gaseous emissions will be from the batch dryer and will be discharged from the main stack via the bag-house. Emissions from the bag-filters on the filler and dust silos and from the bitumen storage tanks’ vents are acknowledged but are considered minor by comparison with those discharged from the main stack.

• The plant incorporates the use of air pollution control that is considered to be in-line with industry best practice: dust emissions from the dryer and the main tower will be captured and directed firstly to a cyclone to remove coarser particulates and then to a fabric filter (located in the baghouse) to remove fine particulates. The filtered air will be discharged to the atmosphere via a 14.3 m high stack. The emission control system has a total particulate collection efficiency in the order of 99.9% (Table 2). The fabric filter will be equipped with an online dust monitor to alert operations personnel in the event of bag leakage or failure.

• The most significant fugitive sources of particulate matter and VOC emission are primarily associated with general materials handling activities such as the loading/unloading of aggregate from the storage bays and the loading of hot mix asphalt product into transport vehicles. Other fugitive emission sources can include wind erosion from aggregate storage bays and truck movements on-site. The DPEMP concludes that the majority of these fugitive emissions are minor in nature.

• The most significant source of odour will be from loading of asphalt onto trucks, including the remainder of the asphalt load-out, up to the point where the truck’s load is covered with a


11

tarpaulin. It is noted that the storage of diesel fuel and bitumen may be a source of odour as a result of working losses and tank breathing losses.

Table 4 of the DPEMP shows the discharge characteristics of the plant, based on design specifications and demonstrates compliance with Schedule 1 of the Environment Protection Policy (Air Quality) (Air EPP) for in-stack concentrations. Particulate Matter is at 50% of the maximum permissible in-stack concentration. All other pollutants listed are at less than 50%.

Modelling undertaken demonstrates a predicted compliance with Schedule 2 of the Air EPP for ground level concentrations. Table 5 of the DPEMP shows that, PAH’s are predicted to be at 26% of the design criterion. All of the other 26 pollutants modelled were at less than 26%.

Odour modelling undertaken predicts a non-compliance with Schedule 3 of the Air EPP, as the 2 Odour Unit1 (OU) contour is predicted to extend into surrounding industrial sites. The peak 1-hour-average odour concentration off-site is predicted to be as much as 45 OU at a location approximately 12 metres from the source (ie at the sites northern boundary) and 5 OU at the boundaries to the east and south.

The DPEMP notes the following:

• The area impacted by the odour concentration above 2 OU is industrial land adjacent to the site and the concentration at the nearest sensitive receptor, Westella, is 1.3 OU (ie below the 2 OU criterion).

• The modelling undertaken suggests that odour emissions are likely to occur mainly during the process of truck loading and covering (tarping) and that the best control for odour during the tarping stage of the process is to limit the time of the emission.

Management measures

Gaseous Emissions

• The drum dryer will be routinely maintained and tuned to improve combustion efficiency (Commitment 4).

• Process controls will be regularly inspected and maintained (Commitment 5).

• The mixing tower will have slight negative pressure so as to minimise blue smoke and odour emissions as the asphalt is loaded into trucks (Commitment 6).

• The bitumen kettles will be fitted with automatic temperature control devices that will be set at the minimum practicable operating temperature (160 – 165 degrees) (Commitment 7).

Dust

• Asphalt Suppliers will use vehicles that have been appropriately maintained such that vehicular emissions are kept to a minimum during construction.

• Measures to control dust release during construction will be implemented. These may include dampening of surfaces, covering of soil stockpiles, and postponement of work during excessively windy conditions.

• The drum dryer will operate under slight vacuum to minimise the potential for escape of dust through seals (Commitment 3).

• Pollution control equipment including cyclones and bag houses will be regularly maintained.

• Available measures identified in the DPEMP to control dust emissions from aggregate stockpiles include; the design of storage bays for reduction of wind erosion, maintenance of

1 At 2 OU some odours may be perceived as very weak while others may be perceived as distinct


12

storage bays, ensuring that storage bays are not overfilled, immediate clean up of spills, damping down of fine material (where required), tarpaulins or other similar covers and chemical stabilisation.

Odour

• To monitor odour impacts, and other potential impacts not considered suitable for on-going measurement, a complaints and incidents register will be developed and maintained and remedial actions taken as appropriate.

• Asphalt Suppliers will adopt operating procedures that include the immediate tarping of all loads to reduce odour emissions (Commitment 2).

• The proponent will implement measures necessary to control fugitive emissions and ensure that only the main stack, truck loading and uncovered asphalt on a single load are significant sources of emission at the site at any one time.

• Should odour become a significant issue additional mitigation measures will be investigated and implemented (Commitment 8).

• The AQA lists a number of available measures that may be investigated should emissions to air (including odour) prove to be an issue. These include bitumen kettles to be fitted with blue smoke extraction devices or appropriate fume absorption devices (eg activated carbon filters), bitumen kettles to be fitted with a vapour recovery system to reduce breathing losses and an extraction system to be fitted on the loading area (which can capture up to 95% of smoke and odour during load out).

Submissions

A number of representations were received concerning air emissions from the activity these can be summarised as:

• Concern about the emission of carcinogenic compounds in close proximity to businesses and homes;

• Concern about the impact of dust on surrounding industries and residences including the inadequacy of proposed mitigation measures

• Concerns about traffic impacts along the route to the site particularly with regard to dust settling on the cars of their workers and customers One public representation raised concern that the DPEMP included no traffic impact assessment dust from truck movements to and from the site;

• Concern about the impact of odour and particles on surrounding industries and residences including the impact on health, the image of the town the financial impact on industries and the impregnation of odours into the final products at the neighbouring bakery; and

• The perceived inadequacy of the air modelling undertaken.

• Concern about increased future production rates and consequent emissions.

A complete list of the issues raised is in Appendix 3 of this report.

The Department of Health and Human Services (DHHS) recommended that due to the potential for dust emissions to be caused by traffic movements to and from the site, dust monitoring be conducted during the commissioning phase of the project.

Evaluation

The plant will have a maximum production of 20 000 tpa (Condition Q1). It is agreed that an increase in production would cause an increase in emissions; however, if in the future, the proponent wishes to increase this production limit approval will be needed (Condition G4).


13

Gaseous Emissions The design criteria for ground level concentrations prescribed in the Air EPP have been determined taking into account the toxic properties of the substances listed and therefore the impacts on health. Due to the use of gas and electricity as fuel and the emission control included in the plant, the plant specifications predict that concentration levels of all potential pollutants are at 50% of these limits or less. Therefore impacts of emissions on health are not considered to be a significant impact of this proposal. The DHHS were invited to comment on the DPEMP and were consulted regarding the emissions of potential carcinogens. They commented that PAH’s are compounds which may be associated with carcinogenic potential but that based on the information in the DPEMP-Appendix C, the levels at which these compounds are expected to be produced (26% of the design criterion) should not pose an unacceptable public health risk.

Dust There is a potential for dust emissions to be caused by the construction and operational phases of the proposal, however, this potential is considered minimal given that the entire area is small (approximately 0.6 hectares) and will be concrete hardstand and given the level of dust emission control that is incorporated into the plant (a cyclone and a baghouse). Table 2 below is taken from the Emission Estimation Technique Manual for Hot Mix Asphalt Plants2 and demonstrates that the proposed dust control measures should be sufficient to control dust.

Table 2: Typical hot mix asphalt plant emission control technologies

The plant and associated emission control equipment should be maintained to ensure that performance is not compromised (Condition A1) and the proponent must control dust emissions from the Land during construction (Condition A2) and operation (Condition A3).

Similarly the potential for dust from vehicles en route to and from the site is limited by the fact that the majority of trucks will be arriving empty and leaving with loads of asphalt which does not present a high potential for dust emissions. The highest potential for dust emissions is from vehicles delivering aggregate material; mitigation measures should be implemented to reduce the likelihood of these emissions (Condition A4).

A complaints register must be maintained (Condition G8) and the Director informed if a dust complaint is received (Condition A5). Due to the short duration of the commissioning phase and the requirements of proposed permit conditions above it is not recommended that a permit condition be included that requires dust monitoring during commissioning.

2 Environment Australia (June 1999) National Pollution Inventory: Emission Estimation Technique Manual for Hot Mix Asphalt Manufacturing.


14

Odour The Division’s air modelling specialist is satisfied with the air modelling presented in the DPEMP and considers it to be sufficiently conservative. The Division’s air modelling specialist has advised that the appropriate odour criterion to be used is that for ‘unknown mixtures’ from Table 1, Schedule 3 of the Air EPP. The 99.5th percentile design criterion for odour emissions which must therefore be met, is 2 OU, at or on the boundary of the Land, with a one hour averaging period.

The odour modelling, based on continual truck loading and presented in Figure 7 of the AQA, shows the 2 OU contour is predicted to extend approximately 150 metres from the boundary into a number of industrial sites and to the far side of the Bass Highway. The batch mixing process is however, by nature intermittent; asphalt is produced to order, in the quantities required, so that each truck loading is a discrete event which is expected to last between 5 and 10 minutes per truck. The proponent has predicted that there will be a maximum of 20 trucks loaded per day.

Figure 4 below (Figure 8 of the AQA) demonstrates the effect of this intermittency on odour emissions. The contour lines illustrate where it is predicted that 2 OU will be met at the 99.5th percentile level. The production level of 20 000 tpa means that on many days there are likely to be less than 20 trucks per day and relatively less odour emissions than those modelled. However, the worst case scenario is for days when there are 20 truck loading events as modelled in Figure 4 below.

• The area contained within the ‘44’ contour (and beyond the activity boundaries) represents the non-compliance region assuming continual truck loading. This is the equivalent of 120 trucks per day at 6 minutes per truck.

• Likewise the ‘264’ contour depicts the non-compliance region for the expected 20 trucks a day, with a 6 minute turn around. The area of potential non-compliance is reduced to the adjacent industrial sites. The bakery to the south is considered the most sensitive of these receptors. The modelling shows that there is a predicted compliance with the Air EPP criterion for all of the bakery property except for a small area to the north east of the building.

Again these predictions are considered conservative:

• ‘Ausplume’ is a fundamentally conservative model when configured correctly. The Division air modelling specialist is satisfied that this model was well configured.

• The dumping process was modelled in a conservative manner using a pseudo-stack source approach. This allowed the use of the ‘PRIME’ building wake algorithm; producing a conservative prediction.

Given the conservative nature of the modelling it is not expected that the Air EPP criteron will be exceeded at the boundary of the property to the south at the prescribed 99.5th percentile level.

If however the criterion is not met under normal operating conditions, there are a range of feasible mitigation measures which are available to capture/control odour (as listed above).

The proponent has made a commitment to investigate and implement odour control measures if necessary and this should be enforced in the permit (Condition A6).

The Director should be informed if an odour complaint is received (Condition A5).

There is a potential for transport of the asphalt to cause odour emissions along the route of transport however this will be transient and limited by the fact that all loads will be covered. This is standard procedure in order to maintain the temperature of the asphalt and is covered by Condition A4.


15

Figure 4: Odour modelling showing the effects of non-continuous emissions (Figure 8 of the DPEMP)

‘44’- Continous Loading

‘264’- 20 trucks per day at 6 minutes per load


16

Recommendations

It is recommended that relevant management commitments outlined in the DPEMP and summarised above are included in the permit.

The following standard (generic) conditions are recommended for inclusion in the permit

G8 Complaints register.

A1 Plant and equipment.

A2 Control of dust emissions during construction

A3 Control of dust emissions.

A5 Covering of vehicles.

A6 Odorous gases.

The following site specific conditions are recommended for inclusion in the permit:

Q1 Regulatory limits.

G7 Commitments.

A4 Dust and odour complaints.

6.2 Noise emissions

Description

Noise will be generated by all stages of the proposal and this has the potential to impact on adjacent industries and residences. A project specific Noise Impact Assessment (NIA) was undertaken and presented as Appendix D of the DPEMP; baseline data was measured at 2 locations; the industry to the north, nearest to the proposed location of the plant, and the residence 250 metres to the south.

Modelling was undertaken to predict noise levels in the vicinity of the site, with emphasis on the four adjacent industries and at the two nearest residences to the south. Full details of the modelling are in Appendix D of the DPEMP.

Construction Noise The DPEMP states that noise generating construction equipment expected on site will include a dump truck, concrete mixer, grader, excavator and a crane. The construction period is expected to last approximately 6 weeks.

Modelling using typical noise levels produced by construction plant such as that listed above, indicates that at times levels of more than 62 dB(A)L10

3 may occur at the nearest residential

receiver. This is a result of construction machinery operating at their maximum sound power, in particular when activities occur with a combined sound power level greater than 114 dB (A) SWL4.

The DPEMP states that ‘this is not an uncommon feature of construction sites but the nuisance is partly alleviated by the fact that site activities are temporary in nature’.

3 The L10 noise levels are those noise levels that are exceeded for 10% of each sample period 4 Sound Power Level (SWL) is a measure of the acoustic power output of an item of equipment.


17

Operational Noise According to the DPEMP the major operational noise source is anticipated to be from the bag filter; other noise sources such as vehicle movements and noise resulting from general materials handling are considered minor in nature. It was concluded that:

• Under general operating conditions the asphalt plant acoustic contribution will be less than 50 dB(A)Leq at both of the nearest sensitive residential receivers (R1 and R2 as identified in the DPEMP Appendix D) even with prevailing north westerly wind conditions (Table 5.4 of the NIA).

• Under general operating conditions the asphalt plant acoustic contribution will be less than 65 dB(A)Leq at 3 of the adjacent industrial sites (I2, I3 and I4 as identified in the DPEMP) but may be up to 77 dB(A) at the industrial site to the north of the project site (I1). This prediction is for the nearest industrial site boundary from site mechanical plant operations, specifically as a result of the contribution from the bag filter dominant noise source.

Management measures

Construction

• Asphalt Suppliers will take every reasonable and practicable step to ensure that the noise impact on the nearest sensitive receivers is minimised at all times.

• Impacts to local residents will be minimised by limiting construction times to between 7:00 am and 6:00 pm Monday – Friday and 8:00 and 1:00 pm on Saturdays.

• Noise will be minimised by the use of well maintained machinery with noise attenuation equipment as appropriate.

Operation

• All equipment and machinery will be operated in accordance with the requirements of Part 3, Division 3, “The exposure standard for noise”, of the Tasmanian Workplace Health and Safety Regulations.

• A noise monitoring survey will be undertaken within 6 months of commissioning of the facility (Commitment 14) and, assuming compliance, on an as needs basis there-after or as directed by the Director, Environment Protection Authority (the Director).

• Asphalt Suppliers will investigate and implement noise attenuation devices as necessary. Appendix D presents a number of potential mitigation measures that Asphalt Suppliers will investigate as necessary.

Submissions

A number of public representations raised concerns about the noise impacts of the proposal these can be summarised as:

• The perceived inadequacy of the Noise Modelling including that readings should have been taken at Westella; that some sources and worst case scenario were not included.

• Noise impacts on local industry and residences including impacts on health and safety and financial impact on industry.

• Concern that ‘a background noise of 45 db(A)’ will impact the health of workers and thus productivity and quality.

• Hours of operation; including that those proposed will impact on the health and wellbeing of occupants and visitors to Westella house.


18

• Noise impacts if work is outside the proposed operational hours ie late evenings and weekends.

• Noise impacts of traffic movements.

A complete list of the issues raised is in Appendix 3 of this report.

The DHHS recommended that noise monitoring be conducted during the commissioning phase of the project.

Additional Information

Following complaints regarding the level of noise reaching Westella from the Bass Highway the Division undertook noise monitoring at this property. A noise logger was positioned at the façade of the building for 19 days during August 2008. The results of this monitoring are relevant to this assessment and details are provided in Appendix 2 of this report.

Evaluation

In order to minimise the impact of noise emissions during the construction phase of the proposal it is recommended that construction activities be limited to 0700 to 1800 Mondays to Fridays and 0800 to 1300 on Saturdays (Condition N1).

The route from the Bass Highway to the site passes through an industrial and commercial area, however in order to limit the potential for trucks to cause noise emissions in domestic areas operating hours should be limited to 0600 to 1800 Mondays to Fridays and 0700 to 1600 Saturdays (Condition G10).

The Division considers that the noise modelling undertaken for the DPEMP was sufficiently conservative in that the predictions were based on the following assumptions: continuous (rather than intermittent) operation; 30 (rather than the expected 20) trucks per day; and that no management or mitigation measures were implemented. The modelling included scenarios with neutral conditions and with a prevailing, north-westerly, wind. It is acknowledged that some general materials handling activities (such as aggregates being dropped into the storage bays), were not included in the modelling but these are expected to be infrequent and minor in nature.

Whilst the nearest sensitive receivers are in areas zoned as rural (Westella) and low density residential (Gumnut Place); background noise levels are already elevated and the area, from a noise perspective, is dominated by significant traffic movement and commercial/industrial activities. This is confirmed by measurements taken at Westella by the Division which show median L90 levels5 of 56.5 dB(A) for daytime hours, 45.8 dB(A) for evening hours and 38.6 dB(A) for night-time hours (Table 1 of Appendix 2). Figure 2 of Appendix 2 shows that noise levels in the area consistently start to rise from 6am. These measurements are generally consistent with the results presented in the DPEMP, measured at Gumnut Place.

The Division considers that the noise contribution from an activity must generally not exceed current median L90 noise levels by more than 5 dB(A). Therefore having considered the noise measurements from the various sites in the area it is proposed that noise from the asphalt plant, when measured at domestic premises, must not exceed 47 dB (A) Leq for early morning hours (0600 to 0700), 55 dB(A) Leq for day-time hours (0700 to 1800) and 42 dB(A) Leq for night-time hours (1800 to 0600) (Condition N2).

These limits have been compared to current L90 noise levels measured at Westella and are presented in Figure 5 below. In the context of the current noise environment these proposed noise limits are generally below the average and minimum L90 levels. It is considered that the plant

5 The L90 noise levels are those noise levels that are exceeded for 90% of each sample period.


19

operation will not be audible for the majority of the time at Westella if noise emissions are kept to within the limits imposed by the permit conditions.

Figure 5: Proposed noise emission limits compared to current noise levels at Westella

Condition N2 also requires that noise emissions from the activity when measured at industrial or commercial premises must not exceed 65 dB(A) Leq. This is consistent with contemporary industry-to-industry noise limits (the New South Wales Industrial Noise Policy6 recommends 65 dB(A) as the acceptable standard for industrial noise at commercial receivers) and is considered to be consistent with the character of the area; industries in the area include industries such as a brick manufacturer, a crash repairer and a steel fabricator and noise levels are elevated by such industrial activity and by traffic movements on the Bass Highway.

The NIA predicts that noise levels at the industrial boundary to the north of the site might exceed this level of 65 dB(A) however given the conservative nature of the modelling and the range of mitigation measures available it is considered that this level can be met. The proponent should demonstrate, prior to construction of the plant, how compliance with the noise emission limits imposed by condition N2 will be achieved: prior to commencement of construction a noise management plan should be submitted to the Director for approval including details of mitigation measures which are to be implemented if required and details of noise measurements to be taken during commissioning to demonstrate the need/effectiveness of such measures (Condition N3).

6 EPA (2000) NSW Industrial Noise Policy

20

25

30

35

40

45

50

55

60

65

70

75

80

00:0

0

01:0

0

02:0

0

03:0

0

04:0

0

05:0

0

06:0

0

07:0

0

08:0

0

09:0

0

10:0

0

11:0

0

12:0

0

13:0

0

14:0

0

15:0

0

16:0

0

17:0

0

18:0

0

19:0

0

20:0

0

21:0

0

22:0

0

23:0

0

00:0

0

Sou

nd p

ress

ure

leve

l (dB

(A))

Time of day

L90 levels at Westella - S-220 - Ulverstone - August 2008

L90-minL90-aveL90-max


20

A noise survey should also be conducted post-commissioning to demonstrate compliance with the emission limits for both residential and industrial receivers (Condition N4). Requirements for the noise survey report are detailed in Condition N5. This is in accordance with the recommendations of the DHSS.

Recommendations

The following standard (generic) noise conditions are recommended for inclusion in the permit:

N5 Noise survey report requirements.

The following site specific noise conditions are recommended for inclusion in the permit:

N1 Operating hours during construction

N2 Noise emission limits.

N3 Noise management plan

N4 Noise survey requirements.

6.3 Water Quality and Erosion

Description

There are no water bodies on the site. The DPEMP identifies the nearest ‘stream’ as Buttons Creek, located approximately 850 m to the west but notes there is an unnamed creek/drainage line mapped approximately 300m from the site. The site contains a number of existing drainage lines.

No water is used in the asphalt mixing process though some water may be used for dust suppression, and in the case of an emergency, the safety shower. The DPEMP concludes that water emissions are therefore limited to domestic wastewater and stormwater run-off which may be impacted by sedimentation, turbidity, and small amounts of hazardous substances (identified in the DPEMP as oil, bitumen, diesel fuels and ‘Truckslip’ release agent).

The DPEMP concludes that the proposed management measures, as detailed below, are sufficient to ensure that stormwater leaving the land is not polluted.

Erosion control The DPEMP concludes that the risk of significant erosion occurring is considered low as the site is flat and will be covered with concrete hardstand in the early stages of the development.

Management measures

• Domestic wastewater from office buildings and onsite amenities will be discharged into the existing sewer system.

• Construction techniques will be employed to divert uncontaminated stormwater away from the site to reduce the amount of contaminated run-off.

• Mitigation measures such as silt traps and hay bails will be employed should inclement weather threaten to cause sediment mobilisation and runoff during construction (Commitment 9).

• The entire hardstand area will be surrounded by stormwater capture drains that direct stormwater through a triple interceptor trap for removal of silt, grease and suspended solids from the storm water prior to discharge into the council stormwater system.


21

• The triple interceptor trap will be of appropriate design and size to handle predicted 1 in 20 year storm events (Commitment 10).

• To ensure the continued integrity of the interceptor trap, periodic cleaning (pumping out) of the interceptor trap will occur in accordance with a maintenance schedule proposed by the supplier of the unit and approved by the relevant authorities.

• A concrete contaminated drainage pad will be established surrounding the plant and for the handling of hazardous materials and spraying of trucks with release agent. A safety shower will also be contained within this area.

• Potentially contaminated storm water from the truck spray area will be collected over the drainage pad, drain into a sump (with a shut off valve in case of spill) and be treated via the triple inceptor trap/gross pollutant trap prior to discharge to stormwater (Commitment 1).

• The pit outlet pipe will be fitted with a manual shut off valve to contain and control any significant accidental spills that may occur (Commitment 11). Should spills during operation of the plant or over application of release agent occur a licensed waste contractor will be used to pump out and dispose of the contaminated liquid.

• Bunded areas will be established surrounding the asphalt tanks and the hot oil heater. Bunds will be fitted with locked valves such that stormwater can be periodically drained and spills can be contained and removed. The bund outlets will be manually operated such that spills can be isolated and pumped out by a licensed waste contractor while clean stormwater can be released to the triple interceptor trap.

• All hazardous material filler points will be located within the tank bund (Commitment 12).

• Hazardous substance spills will not be released from the bunded areas, but will be pumped out by a licensed waste contractor (Commitment 13).

On the 29 September 2008 the Division requested clarification of the proposed water management measures.

On 30 September 2008 the proponent7 responded that they had proposed to release water from the bunds into the stormwater outfall as all water collected in the bunds would be visually checked and only released if free of contaminates. The proponent clarified that water from the retention bunds can drain to the sewerage system if required.

Erosion Control The proponent will develop and implement an erosion management system, which will include identification of the final site drainage patterns and erosion control structures; development of procedures to manage maintenance of permanent erosion control structures and development of a monitoring system to confirm the effectiveness of permanent erosion control structures.

Submissions

One representor raised concerns about ‘the path of surface water egress particularly those channels to East of residential properties.’

One representor commented that the DPEMP did not fully address the Project Specific Guidelines: that the actual liquid waste components were not detailed including the hazardous nature of ‘Truckslip’, that the quantity and quality of stormwater were not fully addressed and that the capability of the triple interceptor trap was not specified. The representor stated that water should be captured and treated before leaving site.

7 Kevin Parker, Asphalt Suppliers Pty Ltd, personal communication with the Environment Division.


22

Evaluation

The Division agrees with the DPEMP conclusion that impacts to stormwater are limited to sedimentation, turbidity and small amounts of general hydrocarbons, bitumen and truck release agent.

The physical characteristics of bitumen; being insoluble, and solidifying if not heated, means the material is considered to present a low risk to water quality, even in the event of spillages. The storage and handling of hazardous materials is discussed as Issue 4 in Appendix 1 of this report.

‘Truckslip’ is described in the Material Safety Data Sheet (MSDS) as consisting of predominantly liquid hydrocarbons with some ethoxylated alcohol, surfactant and silicone additive. The MSDS describes the material as ‘insoluble in water but will form an emulsion’.

Most of the site has a low potential for contamination of stormwater; it is considered that the measures proposed in the DPEMP are sufficient to prevent polluted stormwater from leaving the land. Polluted stormwater must be collected and treated prior to discharge to the extent necessary to prevent environmental harm or nuisance (Condition E1). The stormwater system, including treatment units such as triple interceptor traps, must be of sufficient capacity and designed to treat all stormwater and must be maintained to ensure the capacity is not diminished (Condition E2).

There is a higher potential for contamination of the water that collects in the bunded areas. Due to the very nature of retention bunds all water collected in these areas should not be considered as stormwater and should be considered as contaminated.

The same is true for water collected in the sump of the contaminated drainage pad. The handling of hazardous materials and the application of release agent will take place over this area (Issue 4 below) and water collected in this area should not be considered as stormwater and should be considered as contaminated.

The Division therefore does not support the proposal that water from the drainage pad and bunded areas should be visually checked and released to stormwater if unpolluted. All water from the bunded areas and contaminated drainage pad should be collected and removed from the site or discharged to sewer in accordance with a Trade Waste agreement (Condition E3).

Once the hardstand area is established there is little or no likelihood that the proposal will cause erosion therefore no permit conditions have been included regarding this issue

Recommendations

It is recommended that relevant management commitments outlined in the DPEMP and summarised above are included in the permit.

The following standard (generic) permit conditions are recommended for inclusion in the permit:

E1 Stormwater.

The following site-specific conditions are recommended for inclusion in the permit:

E2 Design and maintenance of stormwater system.

E3 Disposal of water from within bunds

7. Other environmental issues In addition to the key issues, the following environmental issues are considered relevant to the proposal and have also been evaluated.

− Hazardous substances and contingency planning.

− Flora and fauna habitat/threatened species.


23

− Solid and controlled waste.

− Groundwater.

− Cultural heritage.

− Aboriginal heritage.

− Site contamination.

− Marine and Coastal.

− Weed management

− Cumulative impacts.

− Decommissioning and Rehabilitation.

Details of this evaluation, along with recommended permit conditions, are contained in Appendix 1. A full summary of the issues raised in public comment are in Appendix 3 below.

8. Conclusions The Division is of the view that:

(i) the RMPS and EMPCS objectives have been duly and properly pursued in the assessment of the proposal; and

(ii) the assessment of the proposal has been undertaken in accordance with the Environmental Impact Assessment Principles; and

(iii) the recommendations set out in this report accord with the Board’s responsibilities in relation to these objectives and principles.

This assessment has been based upon the information provided by the proponent in the permit application and DPEMP.

This assessment has incorporated specialist advice provided by Divisions of DEPHA in relation to a number of key issues.

It is concluded that the proposal is capable of being managed in an environmentally acceptable manner such that it is unlikely that the RMPS and EMPCS objectives would be compromised, provided that the recommendations made in this report are satisfactorily implemented, including the commitments made by the proponent in the DPEMP.

9. References GHD Pty Ltd; (24 July 2008) Asphalt Suppliers Pty Ltd, Report for Asphalt Plant: Development Proposal and Environmental Management Plan.


24

10. Summary of appendices Appendix 1: Assessment of other environmental issues.

Appendix 2: Supplementary acoustic data.

Appendix 3: Summary of issues raised by public and agency submissions.

Appendix 4: Proposed permit conditions, includes DPEMP Commitments as Attachment 2.


25

Appendix 1: Assessment of other environmental issues

Issue 4

Hazardous Substances and Contingency Planning.

Description of potential impacts

The DPEMP states that small quantities of fuel, lubricants and other chemicals may be stored onsite during the construction phase of the project and that a limited range of dangerous goods will be used onsite during the operational phase. These are identified as: gas for heating the bitumen and fuelling the burner, circulating oil for the hot oil heater, bitumen stored in 2 X 30,000L silos and ‘Truck-slip’ release agent stored in 200L drums.

The DPEMP includes a risk assessment which identifies a medium risk of fire.

Management measures proposed in DPEMP

• Temporary bunding and spill kits will be utilised for any onsite storage that may be required during the construction phase.

• Gas will be stored in a tank in accordance with the manufacturer’s specifications.

• The transport and storage of dangerous goods will be in accordance with the relevant standards and legislative requirements.

• All hazardous materials will be stored within bunded areas in accordance with AS 1940 (Commitment 15).

• The 200L drums of ‘Truck-slip’ will be stored within the truck spraying bay over the contaminated drainage pad.

• Bunded areas will be in accordance with relevant standards and codes of practices.

• Relevant staff will be trained in the use of specific hazardous materials prior to operation and on an as-needs basis thereafter.

• Spill kits will be kept on site in suitable locations and staff trained in their use (Commitment 16).

• Fire fighting equipment will be kept on site.

• Gas (LPG) will be stored in accordance with relevant standards.

• A Safety Management System including an Emergency Response Plan will be prepared. (Commitment 18)

Public and agency comment

One representor commented that the hot oil used for bitumen heating was not defined, that ‘Truck Slip’ is hazardous and explosive and that spills handling is inadequately addressed in the DPEMP. The same representor also commented that the DPEMP did not include contingency planning.

Workplace Standards Tasmania of the Department of Justice commented that the proponent should comply with all relevant acts including the Dangerous Goods Act 1998.

Evaluation

Standard permit conditions H1 and H2 detail the storage requirements for hazardous substances; permit condition H3 details the requirements for spill kits.

The DPEMP acknowledges the release agent as a hazardous material however some handling of hazardous materials, such as the application of this substance, can not practically take place within the bunds. The contaminated drainage pad is designed to capture and contain spills and therefore


26

8 Graham Wilkinson, Chief Forest Practices Officer (Section 4.7.4 of the DPEMP; confirmed by personal communication with Environment Division, 2 June 2008)

it is recommended that all activities that involve the handling of hazardous substances must take place within the bunds or above the drainage pad (condition H4).

These conditions together with the measures outlined in the DPEMP are sufficient to minimise the potential of environmental harm caused by storage or handling of dangerous are considered sufficient including in the case of an emergency or breakdown.

Recommendation

It is recommended that the proponent be required to comply with DPEMP commitments 15 and 16, with standard permit conditions H1 (storage and handling of hazardous materials), H2 (hazardous materials <250 litres) and H3 (spill kits) and with non-standard permit conditions H4 (location of high risk activities).

Information regarding responsibility under the Dangerous Goods Act 1998 to be included in the Information Schedule of the Permit Part B.

Issue 5

Flora and fauna habitat/ threatened species.


Asphalt Suppliers proposes to clear the entire site of vegetation and create a hardstand, to which the plant will be secured.

A desktop survey was undertaken and a GHD ecologist visited the site to undertake a brief inspection. It is noted that a full flora survey of the site was not undertaken or considered necessary due to the limited vegetation values observed during the site visit.

The inspection revealed the majority of the site to be either already cleared or containing exotic species; no threatened flora species were observed during the site inspection.

Two small patches of Melaleuca ericifolia swamp forest, a threatened vegetation community under the Nature Conservation Act 2002, are present along the northern boundary of the site.


No measures proposed.


One representor stated that there was no offset plan for vegetation loss and no evidence of exemption from Forest Practices Planning requirements.

Evaluation

Advice provided by the Forest Practices Authority (FPA)8 was that in this instance, due to the small size of the community, its isolated nature, the surrounding weed infestation and its location within an industrial estate, the Melaleuca ericifolia is not considered a viable community and that clearance is therefore exempt from the need for submission and approval of a Forest Practices Plan. It is not considered there will be any significant impacts to flora and fauna habitat or to threatened species from the proposal as the site is intensely modified and dominated by exotic flora species.

Recommendation

No recommendations.


27

Issue 6

Solid and controlled waste.


Inappropriate handling and disposal of waste can lead to environmental harm or nuisance.


• Waste management during construction and operation will generally be in line with the principles of the waste hierarchy; waste minimisation and recycling will be undertaken where possible.

• Waste construction materials will be stored in a designated lay down yard or in bins located in convenient areas and disposed of regularly to a recycling facility or an approved disposal facility as appropriate.

• The production of waste oil and hydrocarbon waste will be minimized.

• Dedicated and clearly marked bins and drums will be used for hydrocarbon-contaminated wastes. A licensed waste contractor will collect these for disposal.

• Waste material from the maintenance of the interceptor trap will be removed by a licensed waste contractor specialising in interceptor pit maintenance and consigned to landfill.

• All waste disposal will be managed under contract with a licensed waste contractor.

• Monitoring the site to minimise the escape of waste material during certain climatic conditions.


One representor commented that no waste tracking provisions were included in the DPEMP.

Evaluation

The proposal by its nature does not produce significant quantities of solid or controlled waste. Waste material removed during the maintenance of the triple interceptor trap must be collected by an authorised person (Condition E2 discussed in section 6.3 of this report). Therefore it is considered that the measures outlined in the DPEMP together with the permit conditions are sufficient to ensure there should be no environmental harm or nuisance caused by waste management.

Recommendation

No recommendation.


28

Issue 8

Cultural Heritage.


One historic heritage place, Westella, was identified in the vicinity of the Site. This place, a Bed and Breakfast, is located at 68 Westella Drive, on the opposite side of the Bass Highway, approximately 150 metres to the south east of the Site.

The DPEMP includes a Historic Heritage Assessment and concludes that:

• the proposed development will not have direct impacts on the heritage significance of Westella

• that the proposed development will not have a significant impact on the setting of Westella as the relationship of the building to the surrounding open land to the south will be unaffected and its relationship to the coast has been already impacted by the industrial area.


No measures proposed.


One representor stated that the DPEMP did not include a community values assessment of Westella and the impacts on these values. They also stated that the proposal will lead to

Issue 7

Groundwater.


Groundwater may be impacted directly by excavation works intercepting the water table or by pollution from hazardous substances.


The entire site will be concrete hardstand to prevent water infiltrating soils.


One representor considered that groundwater was inadequately discussed, specifically spill management during construction (they considered that a CEMP should be required) and during operations should any areas of the site are remain unsealed. The same representor also raised the loss of water infiltration to groundwater due to the development of the hardstand area.

Evaluation

There is to be no significant excavation at the site, thereby negating the possibility of intersection of the groundwater table. There are to be no underground storage tanks on the site and during construction the whole area is to be converted into hardstand. Therefore the only potential for environmental harm is from spills of hazardous substances prior to the hardstand being established, this is discussed as Issue 4 in this report.

The site is small, approximately 0.6 hectares, hence the loss of water seepage to groundwater is not considered a significant impact of the proposal.

Recommendation

No recommendations.


29

increased industrial impact on the value and amenity of Westella and will directly impact on its setting and therefore its heritage significance.

Heritage Tasmania of DEPHA reviewed the DPEMP and concluded that the impacts of the development on Westella would be minor and difficult to quantify. Their only recommendation concerned limiting the visual impact of the industrial area as a whole; this issue is beyond the scope of EMPCA and should be considered by Central Coast Council.

Evaluation

It is considered that the proposal will not have a significant impact on the heritage values, including setting, of ‘Westella’ owing to the already industrial nature of the area immediately surrounding the proposal site.

Recommendation

No recommendations.

Issue 9

Aboriginal Heritage.


Damage to and disturbance of Aboriginal sites and relics.


If any Aboriginal heritage features are identified during the construction phase, works shall cease and advice will be sought from the Aboriginal Heritage Tasmania prior to re-commencement of works. (Commitment 17).


The Aboriginal Heritage Office (now Aboriginal Heritage Tasmania), DEPHA, did not require a specific site survey but stated that the provisions of the Aboriginal Relics Act 1975 remain applicable if relics are identified during the site works.

Evaluation

There is considered to be only a slight chance that earthworks during the construction phase of the proposal may impact on Aboriginal heritage.

Recommendation

It is recommended that the proponent be required to comply with DPEMP commitment 17 (Covered by standard condition G7). Provisions of the Aboriginal Relics Act 1975 to be included in the Information Schedule of the permit part B.

Issue 10

Site Contamination.


The activity could mobilise existing soil contamination or could cause contamination.


According to the DPEMP there is no evidence of contamination at the site. There will be no underground storage of fuels and the entire site will be hardstand. The measures for storage and handling of hazardous substances are discussed as issue 4 above.


30


One representor stated that there was potential that there was soil contamination at the site.

Evaluation

The Division has no record of contamination at the site and the site history would suggest that it is unlikely that there is contamination at the site. The operation of the proposal is considered to present a low risk of causing site contamination.

Recommendation

No recommendation.

Issue 11

Marine and Coastal.


The site is located approximately 300m from the coast; impacts are limited to the risk of contaminated water draining into the sea via the stormwater system.


Water management measures are discussed in section 6.3 above.


No comment received.

Evaluation

Owing to the distance of the site from the coast, and the water management measures proposed in the DPEMP, the project is not expected to have a significant impact on coastal and marine values.

Recommendation

No recommendations.

Issue 12

Weed Management.


Truck movements to and from site may spread weeds and disease. A number of weed species have been identified at the site including blackberry and thistles.


All existing vegetation will be removed and the entire area will be covered in hardstand.


One representor raised concern that the DPEMP contained no weed management plan.

Evaluation

Weed management is not considered a significant issue for this project as all vegetation is to be removed during the construction phase and the entire area covered with a hardstand.

Recommendation

No recommendation.


31

Issue 13

Cumulative impacts and greenhouse gas emissions.


The DPEMP states that the proposed development is not expected to create any significant cumulative impacts associated with other existing or known developments in the area.

The predicted greenhouse gas emissions are 2 810 tonnes of CO2 per annum including the impact of truck movements.


The proponent will endeavour to minimise the release of greenhouse gas emissions by maintaining the plant in good working order.


One representor stated that the cumulative impacts of the proposal had been considered particularly with regard to the following; noise, odour, greenhouse gas, particulate emissions, groundwater impacts, visual impacts, fire and spill risks and loss of biodiversity power use, water use, traffic and road use,.

Evaluation

The proposed development is considered to have a minimal contribution to cumulative impacts for all the factors listed above. The Division supports the proponent in measures to minimise greenhouse gas emissions.

Recommendation

No recommendations.

Issue 14

Decommissioning and Rehabilitation.


There is no plan for the decommissioning of the proposed facility in the foreseeable future.


In the event that the facility becomes redundant a decommissioning and rehabilitation plan will be produced and provided to the Director at least three months prior to decommissioning.


No comments received.

Evaluation

The measures in the DPEMP together with standard permit conditions are considered sufficient.

Recommendation

It is recommended that the proponent be required to comply with standard permit conditions DC1 (notification of cessation), DC2 (DRP requirements) and DC3 (implementation of DRP).


38

Appendix 3: Summary of issues raised by public and agency submissions A: Summary of Public Submissions. Environmental

Chapter Issue Comment Response 2.1 Proposal Overview.

Concern over potential output of plant in the future. This is a permit condition. Uncertainty of future output and therefore impacts.

3.1.4 Site Contamination.

Possibility of site contamination; soil should be removed.

Discussed as Issue 11 of this report.

4.1 Air Emissions.

Gaseous emissions.

Concern about the emission of carcinogenic compounds to businesses and homes within 500m of the site.

Discussed in Section 6.1 of this report. Odour. Odour (and particles) will affect ability of local industry to

retain and attract employees.

Odour (and particles) may impact on health of workers in nearby industry.

Odour (and particles) will affect sales by deterring business to local business.

Odour (and dust) will affect outdoor activities at local industry causing rise in costs.

Effect on surrounding businesses and entrance to town.

Impregnation of odours into ingredients and final products at adjacent bakery.

Odour and perception/reputation will affect business at adjacent bakery.

Modelling. Inadequacy of air modelling (did not properly account for wind direction, speed, worst case scenario, cumulative impacts from all activities on site and impacts at full capacity).


39

Chapter Issue Comment Response 4.1 Air Emissions.

Dust. Dust emissions (regardless of measures) detrimental to health at nearby receptors.

Discussed in Section 6.1 of this report.

Dust and particles will impact on the on paintwork and interior of parked cars of workers, customers and visitors.

Dust will affect the finish of paintwork and appearance of machinery (new and repaired) at adjacent business when stored outside.

Loading/unloading to and from storage bays (especially with prevailing winds) will cause dust to adjacent properties- water suppression will not be a sufficient measure.

Dust from operations and passing trucks including dust settling on customers/workers cars at site along truck route.

Path of surface water egress particularly those channels to East of residential properties.

4.2 Liquid Waste.

Actual liquid waste components not detailed eg ecotoxicity of Truckslip.


Quantity and quality of stormwater- water should be treated before leaving the site, capability of the triple interceptor trap.

Project Specific Guidelines not fully addressed.

Flood possibility of site not addressed.

Groundwater inadequately discussed (eg spill management during construction CEMP required and during operation if any areas of site are to remain unsealed).

4.3 Groundwater.

Noise if work occurs outside the proposed operational hours.


4.4 Noise Emissions.

Hours of operation.

Proposed hours of operation will impact on health and wellbeing of occupants and visitors to Westella.


Noise readings should have been taken at Westella as this residence is nearer than 3 Gumnut Place.

Modelling. Inadequacy of noise modelling (loading asphalt into truck trays, unloading raw materials, movement/vibration of materials being transported onto conveyors, vibration within plant, full production/worse case scenario).


40

Chapter Issue Comment Response 4.4 Noise Emissions.

General. Background noise of 45 db will impact on the health of local workers.


Current noise issues will be exacerbated; ED baseline findings should be included in the assessment.

Noise, odour and dust impacts (construction and operation) on amenity of occupants and visitors at outdoor function/tourist accommodation.

Noise from operation of machinery and loading/unloading bins may cause loss of concentration leading to injury or inferior products at local industry.

Noise from truck movements and operations.

Discussed in issue 7 of this report.

4.5 Solid and controlled waste.

DPEMP contains no waste tracking provisions.


4.6 Dangerous Goods.

Hot oil for heating not defined, Truck Slip is hazardous and explosive, spills handling inadequately addressed.


4.7 Biodiversity.

Biodiversity; no offset planned for vegetation loss.

No weed management plan included.

No evidence of exemption from FPP.


4.10 European Cultural Heritage.

DPEMP did not include community values assessment of Westella and impacts on these values.


Will lead to increased industrial impact on value and amenity of Westella and will directly impact on its heritage significance (ie its setting).

4.12 Visual. DPEMP inaccurately represents visual impact on setting; photo should have been taken on the western side of Westella and view from upper levels should have been accounted for.

This issue is outside the scope of EMPCA.

Quantitative modelling of visual impact should have been included.

4.18 Environmental Management Systems.

EMP inadequate. Discussed under relevant sections.


41

Chapter Issue Comment Response 4.19 Cumulative.

Cumulative impacts not accounted for including power use, water use, traffic, noise, odour, Greenhouse Gases, particles, loss of water infiltration and impact on groundwater, visual, fire and spills and biodiversity.


Whether dust suppression a valid water use given current climate conditions

General

Amenity of local reserves affected. Discussed under individual issues. Impact of emissions on product and image

of local industries.

Health safety and productivity of local employees.

Contingency planning. Discussed in Issue 4 of this report.

Unpleasant conditions may lead to inability to attract employees and future medical costs.

Discussed in individual sections.

No evidence of Aboriginal Heritage requirements.

Inadequacy of baseline data (air quality, local waterways, traffic loads).

Council/Planning Issues

Chapter Issue Comment Response 3.1 Planning Aspects.

Zoning Light Industrial zoning is not suitable for this type of operation.

These issues are beyond the scope of EMPCA.

Such an activity should not be within 500 m of residential areas nor close enough to cause impacts on industry.

Suggests location in Lloyd’s North Quarry.

No guaranteed vehicular access.

Incompatibility with nearby residential zone.

The potential for sea level rise/flooding of site.

Geotechnical design; area prone to shifting, subsidence and earthquake no consideration of impact of deep/large footings.

Traffic Impacts Trucks should negotiate right-angled corner (near 10 Industrial Drive) at slow speed as there is poor visibility at this point.

No Traffic Impact Assessment.


42

B. Referral Agency Comments Agency Chapter Section/

page Comment

DHHS-Population Health.

General. Recommended regular monitoring of noise and dust during commissioning.

Heritage Tasmania.

Heritage. 4.10

Heritage values may not be directly impacted by these emissions [noise and odour] the enjoyment of the place and its viability may be affected…Having considered the contents of ..[the DPEMP]… it would appear that the development will contribute to a minor degree to existing visual and other forms of environmental pollution and that the impacts on ‘Westella’ will be minor and difficult to quantify.

The single recommendation that we would make, recognising that the development does have some adverse impact on ‘Westella’ is that consideration be given to introducing vegetation belts belts within the industrial area with the primary object of reeducing the visual impact of the industrial area as it is seen from Bass Highway generally and the heritage place specifically.

Workplace Standards Tasmania

General Proponent should comply with relevant Acts and Australian Standards including: Workplace Health and Safety Act 1995; Dangerous Goods Act 1998; Workers Rehabilitation and Compensation Act 1988 and Industrial Relations Act 1984.

34 industrial drive, ulverstone tas asphalt suppliers pty ltd · msds material safety data sheet...

Documents